I'd have to say if you have a credible plan to generate revenue, and are implementing that plan, that's a startup. The rest of it is just means to that end (i.e. parts of your particular plan).
Well, really, I have to agree. I mean, they've been hanging fire on 2. ???? for a very long time now, and probably should have given more thought to the question of project vs. startup before now.
Unless you just want to consider their equity revenue, which is basically how the 90's worked anyway. "End of the business cycle" my ass. I'm still mad about that.
Overall point seems pretty well-taken, though.