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Re:ESnext – Tomorrow’s JavaScript syntax today by girvo on Monday October 13, 2014 @05:03AM (#8447997)
That's because "use strict" is ignored in IE8/9 (thankfully). You usually won't run into any issues, but if you're relying on strict-mode for certain semantics you can run into some very subtle bugs. The chances of that are super low though, I've only ever done it on purpose :)

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