I guess I'm in the minority — in that I don't always use atx-style 
headings.  I switch between atx-[1] and setext-style headings depending on 
the context.  In e-mails and in (plaintext) e-mail newsletters, I generally 
use setext-style headings since those are easily understood even by those 
who don't know about Markdown/atx.  However, in all my other writings, I 
use atx-style headings.  I would support making atx-style headings the 
default.

[1]: I've noticed that all Pandoc and CommonMark documentation uses "ATX", 
whereas the original 2002 blog post by Aaron Swartz uses "atx" as does John 
Gruber's 2004 blogpost on Markdown.

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