I don't think that was the case.
(usual disclaimer, not a lawyer, etc.). CDDL is file based - basically saying "if you modify this file, and distribute the software, you must provide the source code to the modified files".
Sun's intent (as far as I understand) was to appease OEMs by allowing them add additional files to Solaris (think device drivers, etc.) without requiring them to give away the source to their IP.