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"Clickable area" would probably be a good way to count links. I've never been turned down for using a sliced HPA with as many as 9 separate a tags.
On the other hand I have been rejected for a stray a tag that got lost when I was shuffling things around in WYSIWYG mode and wasn't even visible on the page, so I guess you'll always be at the mercy of the particular reviewer.
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