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This technique is a clear “Don’t do Xâ€, in this case document.write and innerHTML. Which would make it a failure technique, except that using document.write / innerHTML is more a question of accessibility support then of conformance to any specific criterion. I imagine this technique was created to inform developers about the innerHTML problem. But it’s done in a format that seems inappropriate for it; as a script technique. For all techniques content can be generated using innerHTML, so limiting this to 1.3.1 seems odd. Also, this technique doesn’t actually provide a solution to 1.3.1. If you were to insert a heading without header markup, that would be an accessibility problem, even if it was done using DOM. It would probably be more appropriate to scratch this technique as it is and create an article in which this problem is explained. This article can then be referenced to from other documents. This comment is part of the project for the Accessibility Support Database.