The HTML generation facilities of the counter package
depend on the html and ncgi packages, but do not
require them or check if they are present.
Either the html generation code should be moved out of
the counter package or be protected with appropriate
checks/lazy pkg requires if html generation is used.
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IMHO putting this into a separate package would be better.
Note that the code currently accesses counter internals.
Separating the two will force usage of public API, and its
possible extension to meet the generators needs.