IBM's Greatest Hits: Exhibit 12, Sept. 2003 -- What code? Exactly where?
We have seen SCO's answers to IBM's Second Set of Interrogatories, but not the text of the interrogatories themselves [PDF], so here it is, IBM's Second Set of Interrogatories and Second Request for Production of Documents, as text. This is yet another exhibit, Exhibit 12, in IBM's list of 597 exhibits in support of its various summary judgment motions -- the motions SCO has acknowledged might mean SCO's case will never see a jury.
When you notice the date, September of 2003, and IBM's simple request -- "Please identify, with specificity (by file and line of code), (a) all source code and other materials in Linux ... to which plaintiff has rights; and (b) the nature of plaintiff's rights, including but not limited to whether and how the code or other material derives from UNIX" -- it's truly unbelievable that we still don't know the answer. For that reason alone, this document deserves to be preserved as text in our collection. This document represents the case in microcosm.