Ok I did it, I read the full text of the law, and you're right.
The existence of Linux or anything not big tech and the broad range of options within seems to be ignored. Does a CLI only OS need to provide a GUI for its "accessible interface"?
On a different note, I did see the last point here:
(f) This title does not apply to any of the following:
(1) A broadband internet access service, as defined in Section 3100.
(2) A telecommunications service, as defined in Section 153 of Title 47 of the United States Code.
(3) The delivery or use of a physical product.
(3) seems to imply the OS that runs your microwave isn't included.