I got sick of manually creating play lists b/c the only way I could figure out how to play non-ASII labeled songs was using the .pla lists. Most of the music in my collection was mislabeled and inconsistent (mp3 tags), so the Sansa was not able to keep all the music under one album/artist title.
What I ended up doing was getting the full version of Media Monkey, and took the time to properly/consistently have the music collection labeled. So now, all that needs to be done is to search for music, select, and send to the Sansa Clip/Clip+. B/c of the properly labeled mp3 tags, I can use the Album/Song/Artist options under "Music" (on the clip), and not have strange and unknown names. So this pretty much accomplishes what a play-list can do, in terms of playing all the tracks of an album, of an artis, etc (including non-ascii labels).
So no more playlist creation for me.