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For most people, Elements will be perfectly acceptable, and is much easier to learn and get power out of than the full CS3. It depends on how much you want to do with your photos how quickly you "outgrow" it. If you're just wanting to convert the photos, do basic color adjustments and sharpening, with perhaps some backscatter removal and other smaller edits, it'll be more than powerful enough. If you want to do more selective edits, including masks or advanced skills (such as what is taught in the Photoshop for Underwater Photographers DVD which has been discussed here before), then the full product will fit your needs better.
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