It all depends on what the definition of "cloud" is...

On Mon, 23 Aug 2004 20:30:54 GMT, "Geoffrey Barnes"
wrote in
. net::

I'm clear on how far away I have to stay from clouds during VFR flight, and
I thought I knew a cloud when I saw one, but...

Cloud is not defined in:

Title 14--Aeronautics and Space

CHAPTER I--FEDERAL AVIATION ADMINISTRATION, DEPARTMENT OF
TRANSPORTATION

SUBCHAPTER A--DEFINITIONS

PART 1--DEFINITIONS AND ABBREVIATIONS


http://ecfr.gpoaccess.gov/cgi/t/text....0.1.1&idno=14


However the Pilot/Controller Glossary contains this definition:
http://www.faa.gov/ATpubs/PCG/C.HTM

CLOUD- A cloud is a visible accumulation of minute water droplets
and/or ice particles in the atmosphere above the Earth's surface.
Cloud differs from ground fog, fog, or ice fog only in that the
latter are, by definition, in contact with the Earth's surface.

So a cloud is fog that is not in contact with the Earth's surface.
Unfortunately, 'fog' is not defined in that document nor Part 1.