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Sometimes when you want to create a new text layer near an existing text layer, you find it hard to actually generate that new text layer because it keeps clicking into the existing one. So let me show you what I mean. If I get my Text tool and I wanted for some weird reason click in between these two text layers and generate new text layer. If you pay attention, you are getting some cursor feedback. So here I have a little dotted line around my I-beam cursor. If you are paying attention, that tells you that when you click, you will generate a new text layer. Okay, I'll hit Escape to get rid of that. When you don't see that little dotted line around the cursor, that means you are going to be clicking into the existing text layer wherever your cursor is.
So again, most people don't pay attention to that feedback. It's especially problematic if you are zooming to way out. If I zoom way out here in a high resolution file, let's say that this is a much bigger file, but you have zoomed way down, there it's really hard to see where you are going to be clicking. So the solution here is if you want to guarantee to generate a new text layer instead of clicking into an existing one, just hold down the Shift key. That will force Photoshop to generate a new text layer wherever you click. So when you definitely want a new text layer, just Shift-click and that will get you what you want.
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