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Defining a title is usually useful, even in those documents that are intended to reside in a frame (meaning that the title would not be displayed since, in a framed environment, the title displayed is that of the document defining the frameset, not any of the titles of the documents within any of the frames). The reason is that you can't know that the document will always be displayed within a frame: the document could be accessed directly from a search engine or from a bookmark, and no framed environment would be present. Hence, the document's title should be defined.