For many statistics and tracking applications all over the internet you need to implement a code snippet containing a noscript tag with a hidden image to make the logging still work if scripting is disabled.  This is done with the <noscript> tag.

But...

In Xhtml 1.0 Strict the noscript tag is invalid for the validator if inside a HTML block element (<p>,<th>,<td>,...).  As a followup to the previous post to make .NET applications Xhtml valid this one is a small addon, but it doesn't require .net, only HTML.

To make a <noscript>...</noscript> tag valid for the w3c validator you should replace it with <object><noscript><div>...</div></noscript></object>.
This weird followup of tags makes it possible to make the page validate.  The object tag makes the use of the <noscript> tag possible in other tags like the <p> tag.
As for most statistics scripts you need to implement, the <noscript> tag contains one single <img ..../> tag.  That would generate another error in the validator because there is no <img/> tag allowed inside a <noscript> tag.  Therefore the div is placed inside the <noscript> tag to make even that little invisible image validate.

Wonderful that this works, it made my search worth the while.

Source: phpCMS Wiki