The engineering problems are tractable even in those cases: Don&#x27;t put the root file system on ZFS.  Develop some kind of first-boot initrd that includes enough of a toolchain to build zfs.ko.  I&#x27;m sure there are other, better ways to solve shipping ZFS in a virtual machine image, especially compared that to the legal and business risks of having a LTS release deemed a copyright infringement: Court costs, legal fees, fines, re-releasing Ubuntu, etc.