It's just an indication to model trainers that they should take care to omit FSF software from training.
Not a nothing burger, but not totally insignificant either.
Is it? The FSF's description of the judgement is that the training was fair use, but that the actual downloading of the material may have been a copyright infringement. What software does the FSF hold copyright to that can't be downloaded freely? Under what circumstances would the FSF be in a position to influence the nature of a settlement if they weren't harmed?
Is harm necessary to show in a copyright infringement case?
Copyright infringement causes harm, so if there's no harm there's no infringement. You can freely duplicate GFDLed material, so downloading it isn't an infringement. If training a model on that downloaded material is fair use then there's no infringement.