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Are the softdevices "special"?

I'm using the nrf51822 evaluation kit. There is low level access (via memory registers) the the 2.4Ghz radio in either a Nordic proprietary protocl mode, or Bluetooth LE mode (I assume the latter means you're basically issuing commands to what the bluetooth spec calls a Controller, but maybe this is where I'm confused).

Are the SoftDevices using anything undocumented in the chip to expose higher level bluetooth functionality, or could I write my own host drivers (implementing L2CAP basically) to talk directly to the radio?

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