I don't think it makes any sense putting the Apache License Header in License 
files.
And do they really want it in the MANIFEST.MF as well?
I checked briefly with Struts2 and it does not contain the Apache Header in the 
MANIFEST file.
It even does not include license files for OGNL, Freemarker, XWork, etc. so why 
do we need to?
Martijn or Henning can you answer this question?
 
Personally I would also not include them in Eclipse Project files.
But surely it can go in the SampleOutput.txt and the .java files where the 
header is missing.
 
Besides the open questions above I would continue with the release, build it 
and offer it for voting.
The incubator PMC will have a look at it again anyway.
Jörg how far have you come?
 
Best regards,
Rainer
 

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