A homogeneous hyperelastic material has a stored energy per reference volume depending on the local deformation gradient but not explicitly on the material point. Its first Piola-Kirchhoff response is
A superposed rigid rotation changes the observer's description without changing the energy of the deformation. Material frame indifference is therefore
This left-rotation invariance is distinct from a material isotropy assumption on right rotations. Differentiate it in an arbitrary matrix direction :
The Frobenius inner product then gives , proving .
For the converse, that stress covariance makes the derivative in of zero. The positive-determinant matrices form a connected set, as also follows from polar decomposition, so this difference is a constant independent of . Composition gives . For fixed , continuity of and compactness of make bounded. But for every positive integer, forcing . Thus stress covariance and frame indifference of the energy are equivalent. Compactness removes the possible additive energy constant in the converse.
For small displacement gradients write . Taylor expansion around the stress-free reference state gives
The linear term vanishes because . Drop the irrelevant constant and retain the quadratic term:
The major symmetry follows from equality of mixed second derivatives. For a skew matrix , stress covariance along gives
Differentiation at zero yields . Thus for every skew matrix, which forces the input minor symmetry . Combining it with the major symmetry gives the output minor symmetry as well:
These identify reference and spatial indices at . Decompose into symmetric and skew parts. Since and the major symmetry also eliminates the other cross term,
Thus infinitesimal rotations cost no energy in the quadratic approximation.
As a function of the full deformation gradient, use . Let , a proper rotation. Assumed full frame indifference would give . For , its infinitesimal strain is . Quadratic homogeneity therefore gives
Choose . Then
The homogeneous deformation changes volume but has zero energy. This illustrates why a nondegenerate small-strain quadratic energy cannot also be imposed as a fully frame-indifferent finite-deformation energy.

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