I love how a never-used-by-courts-before regulation would supposedly already have "most interpretations" with any sort of authoritative value. I can probably walk into a pub tonight and get 27 other "interpretations", they will have the same value of yours. Technically speaking, even the Commissioner's own interpretation might well be flawed - we won't know until a court spends some time on it. I would humbly suggest, though, that when the very same lawmaker who wrote the law is publicly pulling your ears in public on related matters, your interpretations are probably not the right ones.

Apple pay enough real lawyers to defend them, they really don't need pro-bono amateurs.