Gordy - Ah! Thanks very much for that reply. That legal judgement is exactly on my point. The critical phrase, it seems to me, is: "the FAA has not considered the absence of a rating as a restriction on a person's pilot certificate." That is the distinction I was searching for and, as you say, shows that the answer to my question seems to be the opposite of a) what one would expect, b) what you were originally stating and c) what B2N2 subsequently says....unless, of course, the FAA interpretation has changed since that judgement.