Keith: Not quite! For a PDF this may be true, (often it is off by a page or two) For HTML and epub ir does not tell where to go, but offers a link. There is quite a bit of semantic and pragmatic difference. I don't see it? The difference between "telling" how to get there vs. "pointing" how to get there? Evidently, you have not read the documentation well enough or you are not recognizing the fact that the "EPUB TOC" does "tell the reader the major subparts of the whole". Assuming by "EPUB" we mean version 2 since version 3 isn't out in the market yet, I read, direct from IPDF, explaining their transitioning from version 2 to version 3 quote: Need for enhanced navigation support. There is currently no ability to represent preferred instantiations of navigational elements; as well, presently any rendering of page-to-page navigation as well as Table of Contents and other navigation elements is optional and entirely Reading System-dependent. Version 2.0.1 makes "end user" presentation of the NCX TOC a "should" with statement that the next version will likely transform to a "must" and that other NCX sections may receive similar "upgraded" treatment. End-quote. IE a NCX is NOT a TOC under version 2.0 -- Under version 3.0 they are moving to require the NCX to be a TOC. Early EPUBs included explicit TOCs until Adobe Digital Editions started supporting NCX "on the side" in a way that appear similar to a TOC, at which point in time EPUBs appeared to include two TOCs in slightly different incompatible ways that looked stupid, so then publishers began to remove the explicit TOCs from their books and started referring to the NCX as if it were the "TOC." Conversely Kindle retained NCX as in fact a "Navigational Aid" which did not look like at TOC and so instead retained TOCs explicitly in the book where they belong and where they in fact look like a TOC. But then people who naively translated EPUBS to MOBI using Kindlegen would complain that the generated MOBI doesn't include a TOC - of course not since it never had a TOC, rather it had a NCX navigational aid! The NCX is still in there, it just isn't implemented "on the side" like Adobe chose to do making it look like a TOC and not like an NCX. Version 3.0 EPUB basically shrugs its shoulders and says "Oh well the Adobe approach has won out by now."