[ 2018-01-16; Jonathan and Tim Song provide wording ]

We'll have to ask the Microsoft guys if "as by a call to fopen" is OK for them. There are paths that can be represented as a wide character string that can't reliably be converted to narrow characters (because they become dependent on the current codepage, or some other Windows nonsense) so they definitely won't use fopen. But as long as they call something that behaves like it (which should allow _fwopen), I think they'll still meet the spirit of the wording.