In fact, that's the reason why CDDL is not GPL compatible. Because GPL is not compatible with other open-source licenses if the other licenses grant too many permissions to the recipient. Specifically:

GPL prohibits the recipient from static linking with a closed-source product, or using closed-source build scripts. CDDL does not make that restriction. CDDL permits the recipient to build the CDDL code into a proprietary product, and only the original CDDL code and modifications to it must be open source and available under CDDL. All the other stuff that gets linked, and the build process itself, are permitted to be closed source. This is too permissive to be compatible with GPL.

These reasons don't make CDDL incompatible with GPL. GPL is compatible with any license which is at least as permissive as itself. GPLv2 only requires that the recipient be able to receive all of the source code under terms which allow building new binaries (including based on modified source code) and distributed under similar terms. There might be some other reason that CDDL could be considered incompatible with GPL, but not the reasons you mentioned.

I think that the reason that Linux does not want to pick up zfs is more a matter of control and philosophy than actual license incompatibility.

Bob
--
Bob Friesenhahn
bfrie...@simple.dallas.tx.us, http://www.simplesystems.org/users/bfriesen/
GraphicsMagick Maintainer,    http://www.GraphicsMagick.org/
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