Is "Develop" a good term for Ubuntu-based distro?

[Joel Bryan Juliano]

I'm doing a school project, and the evaluator told me that I can't use the
word "develop", since the project will be based on Ubuntu, and he said that
if I'm going to use the word "develop", the project would have to be not
based on anything, even Debian.

In my understanding, develop can have alot of meaning, I think it does not
necessarily mean, from scratch, but if a software developer coined the term
develop to credit a certain project, it might mean that the project is an
improvement or a evolution of the certain project.

Since, Ubuntu is based on Debian, can the ubuntu folks say "We 'develop' a
totally free OS.",
or for other ubuntu based distro, can they say "We 'develop' this new
radical UltimateOS(tm)"
and for my schoolwork, do I have the right to use the term "develop"?
-------------- next part --------------
An HTML attachment was scrubbed...
URL: https://lists.ubuntu.com/archives/sounder/attachments/20060818/94be322b/attachment.htm