The written offer with a limited term of three years is just one permitted method of distribution. If an offer was never made then they're not covered by that clause and are bound to comply by other means without the protection of the three year window.
Yes. I did not cover these cases because approximately nobody does that.
I mean, the absolutely simplest, and cheapest, way for companies to comply with the GPL is to ship the source code together with the software. Stick it in a zip file in a directory somewhere. The company can then forget the whole thing and not worry about anyone contacting them and ranting about source code and the GPL. But no company does that.
The other simple way for companies to comply with the GPL is for companies to provide a link to download the source code at the same place that users download the program itself. If the user did not download the source code when they had the chance, that’s the user’s problem. This will also let the company ignore any GPL worries. No company does this, either.
(The GPL provides a third way for individuals and non-profits, which is not relevant here.)