There's no relation between CGI (the protocol) using the environment and the need to create a CGI object from a HTTP::Request object.

For example, CGI (the module) can already create an object from an Apache::Request object without touching the environment.

In reply to Re^2: Populate CGI from HTTP::Request wo/ using %ENV ? by ikegami
in thread Populate CGI from HTTP::Request wo/ using %ENV ? by renodino

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