<!ENTITY amp "&38;">

[Richard Tobin]

> <!ENTITY amp "&#38;"> is not an error, because built-in entities
> are already defined, by definition.

No, it is an error because section 4.6 says:

  If the entities in question are declared, they must be declared as
  internal entities whose replacement text is the single character
  being escaped or a character reference to that character, as shown
  below.

  [...]

  <!ENTITY amp    "&#38;#38;"> 

[I suppose you could interpret this as saying that "&#38;" is legal
because its replacement text is an ampersand character, but in that
case there is a bug in the standard.]

-- Richard

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