> If you disassembled user32/comctl32 dlls
Yes, I disassembled comctl32. [...] I
believe this action does not violate the Clean Room design.
You are not a lawyer. And even if you were a lawyer, you are not a lawyer representing the project. What you believe does little to impress a team of lawyers hired by one of the largest companies on Earth.
There is a clear set of guidelines on this topic.