http://bugs.winehq.org/show_bug.cgi?id=13554
--- Comment #14 from Philip Nilsson leffeman@gmail.com 2011-07-22 06:05:51 CDT --- Created an attachment (id=35646) --> (http://bugs.winehq.org/attachment.cgi?id=35646) dependency graph
I loaded the program in depends running on Windows XP in Windows 95 compatability mode and had it generate a tree of the module dependencies.
comctl32.dll is a dependency in several places, all of them seem to have in common at least user32.dll->advapi32.dll->secur32.dll, possibly more.