All the articles I read said you could just copy WinHlp32.exe from an XP install. Probably had to takeown to be able to copy over the dummy one in the Windows folder.
Anyway, it's frustrating for me because I know a couple of years back when Vista had that dummy WinHlp32.exe, I found a freeware online that read HLP, HtmlHelp both 1.0 and 2.0.
Maybe the author took it down once MS started providing the WinHlp32.exe for download. I searched everywhere. Seems to have gone to mist. It wasn't Help Explorer Viewer because it was total freeware. Anyway, yet another web mystery.