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Other Approaches
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It might be technically possible to achieve some of the goals using DTDs simply by refactoring the parameter entities (again).
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W3C XML Schema would be better than DTDs.
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I’m not sure the abstraction is right for schemas with lots of mixed content.
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Determinism would still be a problem.
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Local element declarations force customizations to “cascade” up the tree.
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No support for co-constraints.
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Schematron could do it all, but it would require a lot of rules.