For comparison, the OGL 1.0a avoided specific formats: '1.c "Distribute" means to reproduce, license, rent, lease, sell, broadcast, publicly display, transmit or otherwise distribute'
The new ORC from Paizo is clear that any format is fine: "Use or Used means to use material by any means or process that requires permission under the Licensed Rights, such as production, reproduction, creation of derivative works, public display, public performance, distribution, dissemination, communication, or importation, and to make material available to the public including in ways that members of the public may access the material from a place and at a time individually chosen by them."
The various CC licenses are also very clear, eg CC BY: "This license allows reusers to distribute, remix, adapt, and build upon the material in any medium or format, so long as attribution is given to the creator."
So very odd and surely unintended that FTL is so restrictive on this point.