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Recently, I had to change some text on a gif and decided Photoshop, with layers I could turn on and off, would be ideal. I converted the gif to a Photoshop file, activated the text tool, and assumed, per the documentation, that when I created some text, I would also automatically be creating a text layer. I found, though, that no matter what I tried, I couldn't create the text layer in Photoshop.
Finally, I did the text layer creation in ImageReady, where the text layers created themselves just fine. Had to go back to Photoshop to create a background layer... and of course all the masking layers had to be done in Photoshop... so it was back and forth between the two programs.
I can't understand why the text layer didn't appear in Photoshop, though. Damn near drove me crazy. I'd love to master the Photoshop text tool for next time, so all hints would be appreciated.
Also, I never really mastered whatever's necessary to unlock and reposition text layers, something else which would be helpful to know how to do.
The text layer creation will not work in Indexed Mode. (which is common for web files) Switch to rgb mode then when you click with the text tool a new text layer will be created.
Also, be sure you are not clicking on top of or near other text, as the tool will 'think' you are trying to edit this existing text and will not create a new layer.