Do not forget to read the License.
(.... to design, develop and test your programs for use with
Microsoft Windows software)

I think by "Microsoft Windows software" they mean Microsoft Windows itself, not the software used on it... So, even with your definition of wine, using this to further wine development would be a violation of the license.

So IMHO, wine is really a set of API-Testing Programs with some Examples
(in programs). The other Code is only an addon to make our API-Testing
Programs and Examples work on unix ;-)

--
Thanks

Tom

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