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In the link I provided I use JavaScript to push a small text inside a "drawingarea" division (server-side generated) of parent document, when the text contains HTML tags, they're treated by validator as misplaced inside <script>
Just to clarify, the unescaped content is wrapped inside CDATA
...oops, sorry, mea culpa, there was one script call which I didn't wrap- therefore marking as INVALID.