That's not what "recipient" means: it's a term of art. If I want the source code to your private fork of my GPL'd software, and I see your old laptop on Craig's

That's not what "recipient" means: it's a term of art. If I want the source code to your private fork of my GPL'd software, and I see your old laptop on Craig's List, I can't buy the laptop, recover the undeleted binaries from the hard drive, then sue you for the source; this ruling wouldn't affect that.