I'm not contradicting my self at all. I've said more than once that if the content in nav goes beyond just mere links, and if it's complex enough, you can make semantic constructs for that content, which may include lists, but only if lists are required by that content's context.

"Links alone, by definition" comes from the specs:

The nav element represents [...] a section with navigation links.

[...]

A nav element doesn't have to contain a list, it can contain other kinds of content as well.

[...]

User agents [...] can use this element as a way to determine what content on the page to initially skip and/or provide on request.


That makes "Pictures Cookies" good enough, no lists required. That is, is you can break the lists barrier, if you can get past this lists obsession, where you see lists everywhere.