I agree that I feel like I'm not offering it as a service, but according to your quote, "Making the functionality of the Program or modified version available to third parties as a service includes, without limitation, enabling third parties to interact with the functionality of the Program or modified version remotely through a computer network, offering a service the value of which entirely or primarily derives from the value of the Program or modified version"
And that does not actually map on to how I would define "offering the program as a service". I think with that definition it would not be difficult to argue that my ferrets using a webapp are "third parties interacting with a modified version of the program remotely through a computer network", because that is in fact what they are doing.
The fact that this might seem like a ridiculous twisting of the intent of "offering as a service" is somewhat immaterial. I'm old enough to have lived through the SCO trial. Companies and their lawyers, when the company is in need of ready cash, will do a lot of shaking of the couch cushions for loose change, and that includes changing how they interpret previously-acceptable behavior with their software.
Even if one argued that my ferret dating site was offering "value which primarily derives from the value of mongo" and failed to win that suit in the courts, I'd still have lost here - I'd still be on the hook for actually defending myself (or just give in to the hypothesized shakedown).
These are all the fears about open source that came from that first SCO trial and persisted via FUD from the 90s version of microsoft: that using open source platforms somehow opens corporations to legal liability, and it was (in part) to allay those fears that the OSI arose.
That's why I'm concerned about this development. I could be 100% overreacting here, but at the end of the day I am not convinced (with either this or the Redis module license thing) that it is possible to micro-target classical SaaS providers with a commercial-only license situation without collateral damage to self-hosters.