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Currently we consider distance and order in DOM structure. But sometimes these are not sufficient for reasonable choice.
Case 1:
In above case, distance with active element is same each other. So blue element will be selected if it is earlier element in DOM tree, and yellow element will be selected on the contrary.
Case 2:
Sometimes a focusable element can be placed inside another focusable element. In this case, should we allow focus moving to opposite element? Opposite element is not placed in direction, but partially.