The term Dungeon Master (DM) is trademarked by Wizards of the Coast, but plane shift is part of the Systems Resource Document (SRD), which is content that is able to be used and published by anybody under the Open-Gaming License (OGL). In those spell descriptions, the abbreviation GM (for Game Master) is used as a generic, non-trademarked term.
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Minor thing that's more about consistency with Wizards standard than anything.
The spell plane shift uses the term GM on the site instead of DM. The PHB uses DM.
The term Dungeon Master (DM) is trademarked by Wizards of the Coast, but plane shift is part of the Systems Resource Document (SRD), which is content that is able to be used and published by anybody under the Open-Gaming License (OGL). In those spell descriptions, the abbreviation GM (for Game Master) is used as a generic, non-trademarked term.