Disassembling is allowed in the EU in specific cases, these might be
enough to write a free driver.  I don't know how it's done in other
jurisdictions.  People who reverse engineer firmware for other devices
do disassemble it.  All firmware with free replacements has nonfree
licenses, it's not sourceless GPLed code: it's possible to do it and
have it included in distros without getting sued.

I haven't found more information on firmware format except for it being
8051 code loaded at addresses specified in the driver sources, probably
some initial bytes are a header and the code follows.  If you can load
custom firmware and get some output from it, you might be able to find
other useful details from the bootrom or experiments with your firmware.

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