Alas, what I said in context was that the sequence and arrangement of otherwise non-copyrightable elements of sufficiently large header file would likely be copyrightable. In other words, even if you could strip the entire set of header files used in a particular API of any copyrightable elements (a task that is a lot more difficult than it would otherwise appear in a modern API that consists of multiple header files, object oriented programming that combines code with "mere" data structures, etc.), the sequence and arrangement of the non-copyrightable information in such header files is likely independently copyrightable. That is why in clean rooms we usually require the creation of a new API.
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