It seems like the way most people deal with this is to ship a compiled binary that interfaces with the secret code and a larger open-source library that talks to the binary blob. In your case the binary blob would probably be compiled C code that you interface with via XS or
Inline::C. The goal should be to keep the C code as light as you can without exposing the secrets of the memory format.
The alternative is to not sign the NDA and build the interface by reverse-engineering. You could load up the existing Windows implementations and watch what they do with a debugger. Then you can release your code under whatever license you want. (After you talk to a lawyer, of course.)
-sam
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