Ok, I have performed a test of ASCII (0-127) characters, except control characters, and it seems that you can move all keywords containing a non-letter (defined as [A-Za-z]) in the first two characters into 11.html.
I attach the XML dictionary I used for testing, plus the "Italian" Kobo dictionary compiled by Penelope from the XML dictionary. (Note: download the XML file and open it with a text editor, since it might not display properly in a browser, since it has raw "< > &". Penelope does not use a DOM parsers, hence it allows those characters to be unescaped.)
I updated the Google Code source code of Penelope, to reflect tshering's suggestion (thanks!) about 1-character keywords.
Last edited by AlPe; 12-09-2012 at 10:40 AM.
Reason: Added note about the XML file