Mine has at least 100 (that's the estimation - I stopped counting at 54).
And I can't immagine how to work with a keyboard with less letters - the essential "CTRL-ALT-DEL" already counts as 10. And then there are ESC, ALTGR, ENTER, a second CTRL, NUM, several Fs ... and of course the letters in the type and the brand ... .
(slightly more OT: I accidentally poured hot tea over my Das Keyboard, and it quit its services subsequently. Fellow users, take that as a warning... it did not mind coffee or beer, but never hot tea.)
No, that's why I was careful to say the count was only the front of the keyboard. The bottom has some Chinese, and I am uncertain how to count those. Some of the writing on the underside is pretty tiny, too! I'd have to get out my magnifying glass.
Mine was a blankster,now I have 26 letters that my wife wrote on washi tape because I have temporarily (I hope) lost the use of my right hand and it turns out that is very frustrating to type one handed on a blank keyboard.