It's just something about the COM architecture that makes this necessary. Yes, as far as your outlined approach. It may work if you spawn the regular .exe/bat from the COM exe. You just need to experiment with that part. Most 3rd party utilities now-a-days have a COM interface that you could call directly from the mtdll. My experience with mtdll-to-COMexe stems mostly from experimenting with PDF generation and trying to get phdBase to work with COM.