DTD required elements ordering

Question

I want to have list of required elements in any order defined in dtd, but have no idea how I could do this.

For example, I have following definition:

Answer 1

Reading the spec is would appear you can't.

When children are declared in a sequence separated by commas, the children must appear in the same sequence in the document. In a full declaration, the children must also be declared, and the children can also have children.

I think it's because you are declaring a sequence (or ordered list if you like) rather than a collection (or unordered list).