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One thing I noticed in several of the articles I read on this issue
from authors on both sides of the fence was a disturbing tendency to
confuse well-formedness with validity. I am firm in my belief that
well-formedness is a minimum criterion we should not compromise on.
Validity is much more negotiable.
Some times it was obvious from context what the author really meant.
Sometimes it wasn't.
Elliotte Rusty Harold
Effective XML (Addison-Wesley, 2003)