Additionally:

Taken from http://www.w3.org/TR/REC-html40/intro/sgmltut.html which is an overview of looking at SGML
Content model definitions 

The content model describes what may be contained by an instance of an element type. Content model definitions may include:
• The names of allowed or forbidden element types (e.g., the UL element contains instances of the LI element type, and the P element type may not contain other P elements).
• DTD entities (e.g., the LABEL element contains instances of the "%inline;" parameter entity).
• Document text (indicated by the SGML construct "#PCDATA"). Text may contain character references. Recall that these begin with & and end with a semicolon (e.g., "Hergé's adventures of Tintin" contains the character entity reference for the "e acute" character).

Emphasis on "Document text" - PCDATA. Text **may** contain character references. This doesn't imply that all of the four main html entities have to be encoded (<, >, &, and "). Note this document originally applied to HTML but is as relevant to XHTML if you please. The only important consideration is that ampersands be encoded correctly in HTML and XHTML.
--
Paul Connolley - http://shunuk.co.uk/


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