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Yes, they are ordered, but it's relatively easy to come up with a dtd that would allow the import elements to be pretty much anywhere. Furthermore, an Xml Schema Document would be much more appropriate to validate against anyway. The basic issue is if i have a file:
<bean id="some.bean" ... />
<import reosurce="..." />
I want the imported file to refer to the "some.bean". In order to do this with the current DTD, i would have to break "some.bean" out into it's own file, and import both files. It's kind of annoying to have to do it that way.
It's not a must have to be able to put it other places, but it will make the user's lives much easier.