> You can't render MOD songs to MIDI.

Sure you can, both are sequenced music formats, and if you can control the set of samples used to play back the MIDI (which Windows provides APIs for!) you can get it to sound right.

You've gotten yourself into a silly argument here. You're correct that one obvious way to play back a tracker module would be to embed a library that synthesises PCM. But Windows does ship with a MIDI playback engine that allows loading custom sounds. There is nothing unreasonable about converting a tracker module into a combination of a MIDI sequence and a custom DLS bank and then using DirectMusic to play it back.