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It can be frustrating working with text in Photoshop - especially when you want to create a new text layer that overlaps an existing text layer. With the type tool selected, Photoshop will edit an existing text layer, rather than create a new one.
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When you are working with lots of layers, it makes sense to use layer groups so you don’t end up with just a huge list of unorganised layers in the palette. However, as you are building more complex files in Photoshop, the problem you can get is too many layer groups!! I’ve experienced this with very complex compositions and in-particular when I’m designing website visuals.