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This is problem for some debugger plug-in implemetations. Solution: 4.0 - action already moved to debuggercore module 3.5 - dbx debugger module can create a new Toggle action, install it to NB menu and uninstall old one. This solution have to be tested!
It seems to me that this is very similar (the same?) as issue #12583. (It was a defect originaly, it is enhancement now.)
fixed in release35R
Verified ... and Closing all issues resolved into NetBeans 6.7 and earlier.