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   XHTML modularisation causes strange error with MSXML

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I wrote a DTD for a type of aeronautical document, using XHTML
Modularisation. This worked fine until I tried to validate the DTD and
sample documents with MSXML4 SP1 (and earlier). Needless to say they
validate with Xerces and ElCel's xmlvalid (and even with XMLSpy, after
adding a space into empty parameter entities).

I found some messages on xml-dev[1] and www-html[2] related to MSXML in the
context of XHTML m12n and 1.1, but I can't find any solution/workaround for
the following error message (output by xmlint.exe, Microsoft's validator):

    A name was started with an invalid character.
    URL: file:///H:/eAIP/_dev/xhtml/eAIP/sample7-id.xml
    Line 00001: &&
    Pos  00002: -^

As you can expect, that file begins with <?xml ... and not with && or

A page[3] on microsoft.com explains this can be caused by encoding issues,
but it is not my case: I checked the files at byte level to be sure (they
are UTF-8). It doesn't seem to be an OS issue neither (same on NT4 & win98).

I suppose it's a bug in MSXML and I won't wait for MS to correct it for me
So my question is rather: what causes this error? Is there a workaround? (I
am not against a small change in the DTD that would magically please MSXML.)
Should I give up XHTML m12n and instead adapt XHTML 1.0 extensively to suit
my needs? (not that I want to!)

Thanks for any help and sorry for cross-posting,

[1] http://lists.xml.org/archives/xml-dev/200106/msg00502.html
[2] http://lists.w3.org/Archives/Public/www-html/2002May/0036.html

Benoit MAISONNY                        benoit.maisonny@eurocontrol.int
eAIP development & support   http://www.eurocontrol.int/ais/ahead/eaip
EUROCONTROL                        Aeronautical Information Management


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