> 1. Find out if Apache has any interest in this code.

 I think I do :-)

> 2. Find out what legal documents my company has to process for this to
> be adopted.  We have to have our lawyers review this.

I believe that there is a software donation "grant" document for this, but
I'm not the guy to ask abot it.

> 3. Figure out what legal documents *I* have to sign ...

That'd just be a Contributors Licence Agreement (CLA)

Details of both are linked from here http://www.apache.org/licenses/#clas

> Unfortunately I don't think I can make the source available until I have
> our lawyers take a look at #2 so if I can't get an answer to #1 until
> that point I understand.

My 2c is..

If you haven't read it, read this first
http://jakarta.apache.org/site/newproject.html
I guess you have because you're proposing commons which we might assume to
have a lower bar.
However I'd also advise you seriously to consider  incubator.apache.org,
ws.apache.org or xml.apache.org, simply because I believe that they may be
a more appropriate home.



d.





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