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I would not use a JavaScript menu, but the reason for that is not fear of people disabling JavaScript in their browser. I just want to make sure my pages are usable down to the lowest denominator (be that IE3, NN4, or whatever). The level of JavaScript support has change so much the last few years (from virtually non-existing to fully DOM compliant). I just wouldn't be able to justify employing a 100% JavaScript based navigation. The browser quirks are too many and too severe. Besides, most of that can be done with CSS anyway. If you want to use JavaScript for enhanced functionality -- do so. Just use it for a reason. And make sure the page is functional without it.