Distribution License Frustration

I understand a license is not required to bundle the captive AIR runtime with an AIR application but I would also like to bundle the adl.exe file with the AIR application (no other parts of the AIR SDK). The question is simply this: do I need a license to bundle the adl.exe file with an AIR application?
I am having a really difficult time getting an answer from Adobe through the official channels, I have been trying to get an answer for about a week now without success.

Apparently, yes. Since you will be accepting the license agreement on behalf of your end users.

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