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I'd say... possibly, but there's no reason to. An efficiently implemented linear search will waste much less of the limited codesize, and ought to be fast enough, espescially given that the number of search dimensions that make sense to put in a Minibot is small. The first nearest-n-neighbor search bots didn't use kd-trees and worked just fine.

On the other hand... if you're wanting to do it for it's own sake, it would be real neat to see just how small it could get! :)