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This is a just a guess, but in ASCII text files each character is one byte so you may be able to just add up the characters in the html. Note that you will have to include spaces, newlines, tabs, and other special characters which may not be visible in a text viewer.
I would also guess that the calculation is based on the raw, uncompressed html (although mobi/azw containers do use compression) but you would have to test it to be sure.
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