Typically, the In-Reply-To header (if present) is the first hit,
and
when that is missing, the msg-id, and when that is missing, the Subject, or
some heuristics thereof. It's not an exact science.


** In newsreaders, I believe there is often some optionality about how the
various methods of threading are used.  I think, if attempting to thread
email messages, an email client should allow the same. It seems to me that
using the subject heuristically should avoid the problem some are
experiencing, given that some email clients don't even use in-reply-to, and
that some people sometimes change the subject when replying (which is
something humans do naturally in conversation anyway).  Isn't this a better
solution?




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