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In section 10.1, the first bullet point reads: The element must have a height and width greater than 0px unless the element is a text node or if it has a child with a positive height and width. In this context, "child" is ambiguous. It should read "immediate child" or "descendant" depending on what is the actual expected behavior.
we will work with "descendant"
Landed in https://dvcs.w3.org/hg/webdriver/rev/c0bd7d0954ac