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I suggest to deprecate "org.eclipse.ui.help.helpContents". The command "org.eclipse.ui.help.displayHelp" does the same and does not depend (in Eclipse 3.6) on any initialization of Actions.
org.eclipse.ui.help.helpContents also doesn't depend on Actions. Its already been converted to commands (in 3.7)
There is no plan to make this change. Closing.