https://trisquel.info/en/forum/3d-and-free-software-trisquel links to a discussion on Phoronix forums where an AMD employee wrote that they don't document the firmware (called microcode) since it would possibly make breaking its Digital Restrictions Management easier.
They also consider it a part of hardware (maybe some state machine tables used there), so they don't consider to be more free in other GPUs where such things are in the device instead of being uploaded by the driver.
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