That's for lawyers and judges to work out. I will not concern myself with it.
Here is a legal definition: [1]
Making text or code unreadable to secure it for transmission or transport. Both the sender, the encryptor, and the receiver, the decryptor, have the means to translate text or code from source language to unreadable, undecipherable gibberish and back. The devices used have a key that is unique to the sender and receiver.
They used the word key. Our court case will have to decide if chained commands are legally equivalent to a "key". It's not even clear to me that is the universal legal definition. Time and grey wigs will tell. If they decide chained commands are a key that could have an interesting precedence on cases involving protecting users data, banking, military secrets, etc...
I get your point, we disagree.