Hasn't been tested in court to my knowledge, but my understanding is that leading IP lawyers who otherwise disagree on a bunch of things about the GPL (Eben Mog

Hasn't been tested in court to my knowledge, but my understanding is that leading IP lawyers who otherwise disagree on a bunch of things about the GPL (Eben Moglen, Lawrence Rosen) agree that e.g a modified GPLd publicly accessible web server doesn't count as distribution.