http://developer.gnome.org/projects/gup/hig/2.0/menus-standard.html

The phrase "If your application does not operate on documents" has been
misinterpreted.  the distinction that almost any file is considered a document
when we are talking about the document based metaphor (not just the obvious ones
like Office documents).    

The Guidelines need to be tightened up to discourage document/file based
applications from using anything other than a file menu unless they have an
extremely good reason to do so.  

It needs to be made crystal clear that only if your application is not file
based should you even consider using something else besides a File menu.  
The usability (inconsistency) and internationalisation penalty (not using a
stock item, dont get free stock translations) is too high unless developers are
absolutely certain their application doesn't manipulate files.  I dont think
mono-lingual or even some of the bilingual developers get the importance of
keeping consistancy so as not to add to the translation burden.  

Calculators and Games are relatively good examples, but even games that deal
with Open and Saving of game files should be using a file menu.  It is less cut
and dry with an application designed for playing CDs but developers should not
rush into making the change if it can at all be avoided.  

File-Roller (bug 164505), and Totem (bug 160274) which are clearly working on
files should not be breaking consistency.  

(I have a terrible feeling I may have filed this already, we certainly discussed
it on IRC but I quickly searched through all the HIG bugs open and closed but
didn't find anything)