Nevermind. For those who haven't made up your mind, read the judgment above and the actual text of the MA law which points at the same definitions.
I support the position that the information should be available, but the EU RtR regulations are likely to be more successful in driving change vs. MA law., IMO.
I think Tesla has about 18-24 months before we'll see the repair situation change.
Good luck and Happy New Year!
As a matter of legal interpretation, I think you are correct, FlasherZ--if the question were ever litigated, I suspect Tesla would be on firm footing arguing that the law doesn't apply to them.
At the same time, it could very well be that Tesla has decided that it's not worth getting into a dispute about. After all, arguing that this law does not apply to direct sales could supply ammunition to those arguing that the dealer model has pro-consumer benefits.
And as others have said, as a practical matter, the "right to repair" information is basically useless given the other restrictions that Tesla has put on the supply chain, so it doesn't matter much one way or the other.
I think the 18-24 month timeframe is pretty optimistic. At some point, Tesla likely will have to reexamine how it deals with third party repair shops, especially as more and more vehicles age out of warranty. But I don't see that happening soon.