To quote Jef Raskin for a moment:
"Any time 'backwards-compatibility' is given as a reason for doing something,
you may ignore the word 'compatibility'."
There are two things that make the <STYLE> work:
Documents with <STYLE> will presumably be tagged as text/html; version=3.0
and therefore be saved to disk by these old-style browsers.
New browsers (Netscape 2.0?) render it correctly.
The other approach is to use <LINK>, so that there is nothing in <HEAD> with
content, other than <TITLE>.
i.e.
<HEAD><TITLE>...</TITLE><LINK HREF="/foo.css" REL="style">
<BODY>...
Christian "webhead" <*>