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That is not an analogous situation. Keyboard layouts are entirely a software thing. Modern keyboards have zero knowledge of keyboard layouts. Their communications protocol does not deal in keyboard layouts. They effectively speak entirely in terms of ISO 9995-1 key positions and a big bitmap.

* https://news.ycombinator.com/item?id=21915931

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Entirely a software thing? Seems like ISO 9995 and its extensions don't specify anything about the top row of the keyboard (Escape, F1-F24, PrintScreen/ScrollLock/Pause, etc.)

I know that "media keys" (e.g. a Calculator button) aren't actually keys but another kind of USB HID device hanging out on the keyboard like a Touchpoint mouse; but F1-F12 keys really are keys, events sent from the same device that sends regular keysyms. Are they just random non-positional codes hiding out outside the ISO 9995 reserved range?

Yes, entirely. Function keys are not different to the others, and constitute row K. Nor are "media" keys, which are just more keys. Apart from one key, [Fn], they are all just bits in a giant bitmap, indexed by USB HID usage and (usually but not necessarily) partly encoded as an inverted array, on the wire. The keyboard layouts, in software on the host, define the meanings for all of them.

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