IIRC, different APIs in Windows handle special characters for filenames differently.
This was probably around the Windows 98 timeframe, but I remember several instances when extracting zips (probably WAREZ) where the file that was written contained characters that Explorer couldn't handle correctly. It wouldn't allow moving those files to the Recycling Bin, but would typically allow renaming the portion before the extension. I had a collection of `zzzz.???` files for a long time.
It was really common back then to put dates in file names, and names could be 32 characters long. Furthermore, you didn't need an extension because every file had a separate 4-byte (binary, but usually ASCII anyway) type.