That's why I said that if there was a third way to view WotC's PI declaration (I listed only two), that third way automatically seems to implicate WotC in failing to clearly indicate their PI.
What requirement that you clearly indicate your PI? Only OGC must be "clearly indicate[d]".
8. Identification: If you distribute Open Game Content You must clearly indicate which portions of the work that you are distributing are Open Game Content.
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