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The test procedure of H48 just checks whether list markup is used on things that visually appear as list. This implies that the use of lists to tender horizontal menus (as mentioned in example 5 of H48) is not covered in the test. It seems navigation menus just using divs instead of list markup would pass 1.3.1. The same might apply to things like popup menus that may not be perceived as lists (no bullets, no numbering), but the case is clearer for horizontal arrangements. Proposed Change: In terms of a11y it is important to have menus marked up as list. For evaluation purposes, it would be good to have a technique or failure that reflects that. The H48 test procedure might be amended to include a check of navigation menus (incl. horizontal ones) but this may easily become too prescriptive. Not sure...