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ReactOS isn’t based on disassembly of the original Windows code. It’s based on publicly available documentation of Windows APIs (and reverse engineering those that aren’t documented, but that’s a whole different beast from disassembling).

In fact, ReactOS maintains a policy to prevent proprietary Windows source code (whether leaked or otherwise) from making its way to the ReactOS codebase [0]. When Windows source code leaked, in 2006, ReactOS did a complete codebase audit to ensure that it was not tainted.

[0]: https://reactos.org/intellectual-property-guideline/



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