That isn't strictly true, though, is it? Unless you have a flawless memory of BIP39 seed words, you'd need to refer to the English word list.

This is why I'm asking for specific clarification on whether or not the whitepaper is needed. Because "yea you can just look at it" more likely means "You don't have to buy it, you can just use a jpeg/png version" but still requires outside information.