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If I save layer files in ArcGIS 10, can they be opened and modified in ArcGIS 9.3?

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No. I receive this error in 9.3.1:
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You have to save them at the correct version. Right-click on a layer, select Save As Layer File...
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Then use the Save as type drop down list to select different versions of layer file.

Updated Screenshot of the Save Types

1

ESRI products is not backward compatible, as a workaround save as the layer file at version 9.3.1 to open and edit the layer flie at 9.3.1.

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