I have taken one of your todo.xml file (that contains just the following
lines
        <list module = "catalog">
        </list>
  and let's netbeans generate the DTD.
    here is the generated DTD
          <!ELEMENT list EMPTY>
          <!ATTLIST list
            module CDATA #IMPLIED
          >
   as you can see, the Element list is considered as EMPTY.

 if you ask to validate the XML file, system say it's not valid because list
is not empty.
The reason is that CR/LF is something for the parser and then the list is
not empty.
Is it a problem with the parser ?
Is it a mistake by generating the DTD ?