The very text of the GFDL which you quote gives permission for translations as the *only* kind of derivative work possible for Invariant Sections: in particular, annotations are not permitted.
Either way, we've gotten way off on a tangent. The GFDL does not meet the DFSG. I present two pieces of evidence: 1. Invariant Sections fail DFSG points: 1. Multiple DFSG works on different subjects, all with the Invariant Section "Why Free Software Needs Free Documentation" may not be combined into a book "Free Documentation For Free Software," as the Invariant section would no longer be Secondary. 2. The transparency requirement allows distribution in some compiled forms (e.g. plain text) but not in some source forms (e.g. MS Word) 3. The license does not allow arbitrary derived works: indeed, it prohibits any derived work but translation for some sections, and it universally forbids excerpts 4. There is no explicit provision for patch files to modify Invariants. 6. Those fields of endeavor which suffer from tight restrictions on space or bandwidth are discriminated against by Invariant Sections. 2. The clause regarding technical measures to prevent further copying violates DFSG points: 6. The license discriminates against use for Digital Rights Management technology. 5. The license discriminates against the manufacturers of DRM-enabled storage devices. 1. A copy may not be made into a protected environment: this means the document may not be freely distributed. Do you have any refutation for this? Not "The DFSG doesn't apply to documentation" -- I've just packaged up SniffMacs, my set of TECO macros for nasal manipulation, and wish to distribute it under the GFDL. Can Debian distribute it? Even if it has Invariant Sections? -Brian