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.

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