Accessing data - Manipulate XML data structures

You need to use an ampersand in the name of an element you create with an XElement item. Which of the following allows a correctly created element name?

Just pass in the string to the XElement constructor; it handles it automatically by calling the XmlConvert class transparently.
Use the XmlConvert.Encode method to create the string to pass into the constructor.
All of the above.
Manually escape the character sequence.