Comment obviously not clean-room (Score 1) 125
"Clean-room" means you have one group of engineers study existing code and create a specification and then another group of engineers takes that specification and writes new code that does what the original code did. This is because copyright protects expression, not ideas, AND that independent creation of the same expression is not infringement either.
If you have the same person reading the old code and writing the new code, then to whatever extent the expression is similar there is no protection under copyright law. If this harebrained process was enough to get around copyright law, then anyone translating a book into another language wouldn't run afoul of copyright law.
Here you have the same harebrained process only with a computer doing the reading and writing not a person, but that changes nothing because the expression of the input can affect the expression of the output. If there's a lawyer who signed off on this, he should really find another line of work like traffic court defense.