My thoughts on the white paper...
1. I would like more specifics on the "N activations in M locations per [time period]". I note that, so far, this principle is being inconsistently followed in the Impulse store. The product page for Sacred 2 contains a "Protection" line that specifies the use of SecuRom and two (presumably simultaneous) activations with unlimited re-activations. Such a Protection line is completely absent from the product pages for The Witcher, Hinterland or Europa Universalis III.
If you are going to allow each product on Impulse to essentially mix-and-match their own DRM, then that "Protection" line needs to be visible on every single product page, even if it says nothing more than "Impulse-standard e-mail and serial number activation" (or words to that effect).
2. I'm reaching a little here but, as a consumer, I would like the ability to both see my current activation status for a given product (i.e., a screen that says something like "2 of 3 simultaneous activations in use; 7 activations of this license all-time) and have a clear process for "getting back" those activations if I have a hard drive failure or similar. In other words, you should only allow publishers to set their own (restrictive) activation limits if they commit to making those limits transparent and easily correctable for legitimate users.
3. Tying policies to the Gamers' Bill of Rights is problematic. The last edition of the GBoR was the "interim" one published in your 2008 Customer Report (unless I missed one, in which case please link me!).
The content was obviously still a work in progress and it contained a lot of vague verbiage such as "materially", "adequately" and "within reason". Those concepts need to be quantitatively defined. What is the definition of adequate performance? Who will determine it? How will you ensure you get accurate measurements? Will there be a specific set of conditions (such as the game resolution or which/how many non-game processes are running) that the gamer must check before complaining about inadequate performance?
You also need to get consensus on an enforcement scheme for when developers ir publishers are found to be in violation of the GBoR. Some will be as simple as refusing to carry games with too-restrictive activation schemes on Impulse at all. But what, in exact and concrete terms, will you do if a non-Stardock game carried on Impulse is found, after release, to have "defects that would materially affect the player experience"?
Until these sorts of issues are addressed, the Gamers' Bill of Rights, despite being a great idea, will remain a toothless PR ploy of absolutely no value in terms of guaranteeing gamers that they're buying products of particular quality. After all, it will be easy to get publishers to agree to rules that they know they're never going to be penalized for breaking.