I don't think so - the retail version of Fallout 3 uses Games for Windows Live for DRM and achievements.
Actually it uses Securom. Surprise, surprise. Though only a disk check version of it.
I don't think you can actually call GFWL a DRM either since it did nothing to protect tie DLC files which allowed for the "offline mode" usage once you bought them. Albeit the DLCs were downloaded to some secluded folder in the bowels of your computer, though thats hardly anything to mention.