Well, that interpretation certainly makes sense. And, my IA may have had it wrong. IAs do seem to disagree a lot.
When I was purchasing the airplane, Don Maxwell did the prepurchase inspection. He had done some work a while back on the plane replacing a wingtip, outboard wing skin and a rib due to a hangar door incident. I had another IA of about Don's years of experience review the logbooks. He said that the repair should have a 337. Don said it didn't need one because he just replaced some parts with new factory parts. I asked a third IA that is director of maintenance at a large Part 135 operation and he thought about it for a while and agreed with Don, but said he wouldn't find fault with someone who thought a 337 was warranted. I'm lucky to have two experienced IAs on my home base and if I don't like the answer I get from one, I go ask the other. Sometimes they agree; sometimes not.
But then all the FSDOs don't agree with each other either. That's why you get an STC for Rosen sun visors and don't need one for GLAP windows. From GLAP FAQ:
Q3: Why are your thicker side windows not STC'd?
A: Our regional FAA has determined where STC's are to be applied. Keep in mind that not requiring an STC keeps the paperwork down and a 337 form is not necessary. We have been told by our regional FAA office that STC's have been overused for minor changes, thicker side windows are considered to be a minor change by our regional FAA office (Chicago).