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Building a DLL for MSVC5/6

Kurt Z. stated:
  You can build using MSVC5/6 or mingw32 or cygwin.
  With MSVC5/6, only static libraries will be built,
  (we need to port mingw32 DLL support to MSVC5/6)

Does this imply that mingw32 is required to build a DLL?
Is there a reason MSVC5/6 can't?