I am glad Mike offered some email responses to help forward his position.

I have never thought valid code is needed to rank as that is easy to see with the naked eye in the SERPs everyday. One area I was gray on is if valid code at least "helped" websites rank better and that seems to be untrue from the responses here. Of course I am not talking about crawlability, but simply one website having valid code and one not having valid code with all other items being equal.

Still I will look to limit validation errors just from a design perspective as Webnauts suggests.

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