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An html toc doesn't have to be defined as a NAV document to be a ToC that a user can use to navigate the epub in question. There are tons of commercial EPUB3 books out there that use the NAV document as a sort of "mini-toc"--complete with a landmark that is a link to a more complex (and navigable) table of contents. Much like KevinH mentioned, each of your landmarks in the NAV could be a link to a more useful html toc. Those additional html tocs just can't be created as NAV documents.
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