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Based on Brian Kardell's email to public-webapps: * The upper-boundary encapsulation (http://dvcs.w3.org/hg/webcomponents/raw-file/tip/spec/shadow/index.html#upper-boundary-encapsulation) constraints do not mention CSSOM extensions to Document interface (http://dev.w3.org/csswg/cssom/#extensions-to-the-document-interface). * They should be included to the constraints to also say that you can't access stylesheets in shadow DOM subtrees. This also implies that style blocks, defined inside of a shadow DOM subtree should have no effect on the document, and unless the style block has a "scoped" attribute, it should have no effect inside of a shadow DOM subtree, either.
http://dvcs.w3.org/hg/webcomponents/rev/2a1cb3e930b2