That would be a very odd interpretation of that phrase --- because when one usually thinks of "access control" and the DMCA, circumvention is about allowing access to copyrighted work. Adblocking is essentially all about disallowing access.

But if that interpretation does hold up in the courts, it could lead to a very slippery slope where it becomes illegal to refuse to consume specific content. The equivalent of not being able to change the channel on the TV or go do something else when the adverts start, or even... just close one's eyes and ears.