XHTML 1.1

In the DTD there is a peculiarity I'm having a hard time getting around.  Perhaps you can make some suggestions.  The following is OK for the W3 HTML Validator which honors IGNORE over "inaccessable or does not exist".  However, in trying to do validation with MSXML4 this triggers an error.  I guess MSXML4 looks for the document first, then ignores it.
  
<!-- Pre-Framework Redeclaration placeholder  .................... -->
<!-- this serves as a location to insert markup declarations
     into the DTD prior to the framework declarations.
-->
<!ENTITY % xhtml-prefw-redecl.module "IGNORE" >
<![%xhtml-prefw-redecl.module;[
%xhtml-prefw-redecl.mod;
<!-- end of xhtml-prefw-redecl.module -->]]>

While I can see the logic (and virtue) in both interpretations,  I would like to know which one is correct.

Thanks,

Gannon J. Dick