Question: Is secdrv.sys a "Protection Mechanisim"

[Jonathan Wilson]

My argument is that it is not a "Protection Machanisim" as defined by the DMCA.

IANAL but from reading the DMCA information on various places (including 
the act itself), the folowing is true:
1.an Access Control Measure is something that prevents unauthorized access 
to a Copyrighted work.
2.Therefore, in order for someone to have "circumvented an access control 
measure", it means that whatever they have done makes it possible to make 
and/or use an unauthorized copy of a copy protected work.
3.Therefore, by extention, any tool that is illegal under the DMCA must:
A.allow soneone to make and/or use an unauthorized copy of a protected work 
in a way that is not possible without said tool.
or B.be capable of being modified to enable A to happen.

IANAL or a windows-kernel-mode-guru but from my reading of secdrv.sys clone 
code and also secdrv.sys itself in a disassembly, its sole purpose is to 
provide access to kernel-mode memory necessary to identify SoftIce (and 
probobly other similar kernel-mode debugger). And, assuming this is true, 
no modification, re-write, clone, stub or replacement for secdrv.sys will 
enable someone to make and/or use an unathorized copy of a protected work 
in a way that is not possible without said special secdrv.sys. Therefore, 
the wine secdrv.sys is not a violation.

Therefore, 1 of 3 things is true:
1.my interpretation of the DMCA in the paragraph above is wrong
2.it is correct but my interpretation of what secdrv.sys is wrong (and in 
fact there is a way to use a modified/re-written/cloned/stubbed in 
wine/whatever version of secdrv.sys to make and/or use an unauthorized copy 
of a protected work in a way that is not possible without said version of 
secdrv.sys)
or 3.neither of 1 or 2 is true and therefore the clone of secdrv.sys is not 
a DMCA violation and can go into the WINE tree.

Feedback from anyone that knows more about either the technical aspects 
(i.e. just what secdrv.sys actually does) or the legal aspects (i.e. what 
the DMCA says counts as a tool that circumvents an access control measure) 
would be good.