I think Crockford is right about that error.

Declaration of variables in the loop could lead to this type of error:

http://cam.ly/blog/2011/01/javascript-interview-question/

(All of the 4 <li> will do alert('4') when clicked, when the programmer expects alert('1'), alert('2'), etc.)

If the variable had been declared at the top, that error probably would not happen.