Yes,but in this way it still don't have some keys.
I think, that's best way to add two virtual modifiers - one for CTRL, second for FN.
For example you click on CTRL modifier and on real keyboard on C key -> emulates CTRL+C. Second press on key C only C.
FN modifier keys:
In this way is possible to emulate all keys without too much cursor moving on virtual keyboard.
What do you think?