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Sections 3.1 and 3.2 of the CeCILL, edited and with emphasis added:

3.1 The Licensee shall be deemed as having accepted the terms and conditions of this Agreement upon the occurrence of the first of the following events:

  • (i) loading the Software by any or all means, notably, by downloading from a remote server, or by loading from a physical medium

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3.2 One copy of the Agreement...has been provided to the Licensee prior to its acceptance as set forth in Article 3.1 hereinabove, and the Licensee hereby acknowledges that it has read and understood it.

If a distributor, be it the Licensor or a Licensee, simply offers a download link to CeCILL-licensed software without first directing the user to the license, have they done anything wrong?

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A licensee depending on the license to permit their distribution of the software would be, but it's strictly a matter of their having violated their license. The copyright holder would have to take action against them for copyright infringement for it to matter. The copyright holder themselves could offer a download link without providing the license because they can't infringe on their own copyright, but it's inadvisable to download software without knowing the license terms first (due to the risk that the software may not be licensed for distribution and downloading a copy would technically infringe on it's copyright).

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