Main
Symmetric Multi-Processing
This document, dated the 23rd day of October 20003 (sic), listed 591 files "which may, on information and belief, include information (including methods) that IBM was required to maintain as confidential or proprietary pursuant to contract with SCO and/or which constitute trade secrets misused by IBM are found within Linux 2.4 and/or Linux 2.5 kernels under the following source file headings". There followed what was apparently a lightly filtered list of every file in the Linux 2.5.69 kernel [download] that contain the words "SMP", "RCU" and "NUMA", plus all the JFS files. See Frank Sorenson's superb analysis. Of those 591 files, 520 files contain the word "SMP", including the celebrated include/asm-arm/spinlock.h.
In this document, the Revised Supplemental Response, no SMP files at all are listed, and the best they could come up with is this:
As admitted by IBM, it is actively working with the open source community to improve Linux performance in large-systems for enterprise use, particularly through advanced use of SMP sequences and structures. [...] However, performance improvements such as SMP are not readily visible from evaluation of the Linux codebase alone. Plaintiff needs complete discovery from IBM to fully identify all of the ways in which IBM is contributing methods, sequences, structures and code to Linux SMP and other performance enhancements, and to fully identify the degree to which IBM is improperly using Protected Materials in making such enhancements.
The accompanying Declaration of of Ryan E. Tibbitts (document 97) said: "20. In order to fully respond to the Interrogatories, SCO also requires complete disclosure by IBM of all of its contributions to Linux, including: [...] A description of all SMP or other multi-processor enhancements made to Linux by an IBM engineer, employees or contractors, together with the precise location in Linux that the enhancement was made, and the date thereof".
The subsequent Hatch letter of 19 April 2004 (157-28) listed no SMP files at all.