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],

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.