Your interpretation sounds valid but I'm highly sceptical since it appears to be a loophole that undoes the entire purpose of the AGPL. You have to be careful about being right in technical terms but wrong in substance - as in the classic exchange on GPL from Stallman:

http://clisp.cvs.sourceforge.net/*checkout*/clisp/clisp/doc/...

The kicker being (Stallman's words):

"What the lawyer said surprised me; he said that judges would consider such schemes to be "subterfuges" and would be very harsh toward them. He said a judge would ask whether it is "really" one program, rather than how it is labeled"