[jan-jaap]

Nothing proposed or offered is in any way a violation of US law.

IANAL, but I think that's a pretty bold claim.

First of all, you're likely breaking the license agreement if you even install IRIX because you neither "paid applicable license fee", nor "bought an SGI workstation or server" (from the license holder, namely: SGI). Effectively you're starting your effort from an illegal copy of the software. This is a problem because the DMCA states "The procurement of the reverse-engineered product must be through legal means and the person must be the lawful owner of the product."

Then there are restrictions on your right to make copies of the software. Making a copy of the software for the purpose of of reverse engineering is not allowed and has been used to sue. The EFF explains it better: https://www.eff.org/issues/coders/revers...eering-faq

Of course the license explicitly forbids reverse engineering, but so does the law in Europe and the US. There are exceptions (interoperability for example), but unfortunately 'retrocomputing hobbyism' isn't one of them. Commercial motives of "businesses that still use IRIX" certainly aren't.

We will not be releasing any of HPE's proprietary code and we will be following all best practices and ethical guidelies.

That depends on the method used.

Clean Room Reverse Engineering is the only method that has successfully stood up in court (see SEGA vs Accolade). In this case, the disassembly team would have to be all first-owners of SGI systems (in order to satisfy the DMCA). Good luck with that.

But I have the feeling you're more thinking of running the kernel object code through IDA Hex Rays and massage it into something that compiles, a.k.a. Dirty Room Reversing. Legally, unfortunately, this is the equivalent of converting a JPEG into a PNG: you're still creating an unauthorized copy of a copyrighted work.