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You are correct. 107.39 is clear enough even an FSDO can understand it.
§ 107.39 Operation over human beings.
No person may operate a small unmanned aircraft over a human being unless that human being is:
(a) Directly participating in the operation of the small unmanned aircraft; or
(b) Located under a covered structure or inside a stationary vehicle that can provide reasonable protection from a falling small unmanned aircraft.
An operation that flies directly over people inside a parked car certainly meets the criteria in (b) above.
§ 107.39 Operation over human beings.
No person may operate a small unmanned aircraft over a human being unless that human being is:
(a) Directly participating in the operation of the small unmanned aircraft; or
(b) Located under a covered structure or inside a stationary vehicle that can provide reasonable protection from a falling small unmanned aircraft.
An operation that flies directly over people inside a parked car certainly meets the criteria in (b) above.