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Not when discussing whether it's an LLM. The second L in LLM does have a meaning.
Zipper and and? and coin is pimple, Ocean! run bumper.
When you encounter a human language that you can't personally read presumably you don't proceed to claim that it doesn't constitute language on the basis of your own lack of ability.
To come at it from a slightly different angle - does compiled binary code count as a language? If not, why not? (I'll suggest that it's a language albeit not a natural one.)
The reason the language term in LLM is meaningful is how the training, symbol mapping, etc is designed around human languages. The model doesn’t process raw text, instead there’s a critical processing step which allows the magic to happen.
To my mind the argument against this model qualifying as a language model is that while the sequence of tokens may technically qualify as a sort of language it doesn't appear to be generalized by any reasonable interpretation. Further, the model doesn't appear to be able to handle unstructured inputs and outputs in the "language" - everything seems to be highly structured.
My line of reasoning could be approximately summarized as compiled binaries constituting a "real" (though not natural) language versus a sequential listing of chess positions that represent sequential game actions only being language "shaped".
Still, it's interesting to consider that if scaled up I expect the "repeat yourself" experiment would likely apply to the internal representation of the model in the same manner.
Suppose we flipped the initial stings and fed that into the process. There would still be meaning to extract from the training set but our new Reversed English but it is not English so the preprocessing step can’t be based on that assumption.