[ECOS] Clean room module loader + GPL module + Application

["C.J." <tsai.cj@msa.hinet.net>]

Hi,
I know eCos mod-GPL have been discussed several times.
I also understand that eCos is not GPL compatible --- 
Using GPL code in eCos kernel will force the license 
of eCos application GPL.

GNU GPL (http://www.gnu.org/copyleft/gpl.html) states:
   The source code for a work means the preferred form of the work for making modifications to it. 
   For an executable work, complete source code means all the source code for all modules it contains, 
   plus any associated interface definition files, plus the scripts used to control compilation and 
   installation of the executable. 
   However, as a special exception, the source code distributed need 
   not include anything that is normally distributed (in either source or binary form) with the major 
   components (compiler, kernel, and so on) of the operating system on which the executable runs, 
   unless that component itself accompanies the executable. 

Considering only legal issues (just ignore any technical or code size issue), 
If an eCos system is implemented like this:
(a) eCos kerenl (mod-GPL)
(b) Clean room module loader  (closed license)
(c) A GPL module registers itself as "/dev/storage" (GPL)
(d) Clean room application, mount  "/dev/storage" and use eCos POSIX layer (via FAT filesystem) 
      to access the device (closed license).

Does the GPL "special exception" apply to this situation?
Is it legal If the provider do not release the source code of  (b) and (d)?

Best Regards,
C.J.