Alan Cox mentioned that "No we can't. The GPL ZFS bits don't include the
various methods that would violate the patent so there is no grant."

Couldn't we just use the GPL ZFS source code in GRUB to create a
minimalistic implementation of ZFS that did not violate any patent, yet
would be more useful than no implementation at all?

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Add native ZFS to Ubuntu
https://bugs.launchpad.net/bugs/202952
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