Please allow me to highlight the depth of the "automatic liability," as you describe it. Two paragraphs from my document should suffice to highlight this. 1.) The Introduction to WCAG 1.0 is quoted as follows: "The guidelines address two general themes: ensuring graceful transformation, and making content understandable and navigable." 2.) At the beginning of my ANALYSIS section in message 2 of 3 there is this: It is worthwhile to note that by definition, <PRE> exists in tension with the basic themes underlying web accessibility as expressed in the WCAG. By definition <PRE> does not "gracefully transform" to any other presentation. It's very purpose is to lock in a particular presentation. Nor can it assist accessibility by making larger blocks of text "understandable and navigable." It allows no navigational elements within its bounds. Furthermore, people whose comprehension is challenged by larger blocks of undifferentiated text can be expected to have greater difficulty accessing content bounded by <PRE>.