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The throw must be a quality throw in OBR. The interference is actually with F3's right to catch the ball, not with the throw itself. A throw over F3's head is not a quality throw and F3's right to catch the ball has not been interfered with.
FED has this situation in the 2004 Interps:
SITUATION 20: As B1 bunts, F2 fields the ball in front of home plate in fair ground. B1 is running in fair ground as he nears first base. F2 realizes he does not have a line of sight to F3 and tries to lob the ball over B1. F3 leaps but cannot catch the ball. RULING: B1 is out for interference. Although F2 made an errant throw, B1 is guilty of interference by being out of the 3-foot running lane. (8-4-1g)
So one might conclude that FED wants to be different, again. Maybe in the interests of safety they don't want the catcher to be penalized for not plunking the runner in the back.
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