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Depends on the requirements IMO. Creating via DOM can advantageous if further manipulation via the DOM is required. This will remove the overhead of creating a string and the initial parse to a DOM object. If you data source is correctly encoded and standardised you can create XML documents more efficiently by using strings. 1) Creating a XML string by hand can become cumbersome, if XML is Program logic can overcome the "by-hand" issue.
I guess this depends entirely on experience of the developer in regards to XML. 3) Using DOM API can check well-formedness of entities (like, &abc; This certainly is a major benefit; like a interpretted language you get to see where you go wrong as you're constructing the DOM object.
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