If we're both pointing head to wind, does anyone have right of way?

Yes. The definition Leeward and Windward keeps you on the tack of your windward side until you turn past head to wind — pointing at the wind changes nothing. So the boat that was on port is still on port, and Rule 10 makes her keep clear. A gradual luff also satisfies Rule 16.1, because the other boat still had room to respond.

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