No, there is firmware inside the wifi. Just looking at a specific chip ath9k wifi device: https://www.qca.qualcomm.com/wp-content/uploads/2013/11/AR94... I see it has a "32-bit Tensilica Xtensa CPU" and this CPU is running some proprietary firmware on the embedded Code ROM. Although this firmware cannot be updated, is completely isolated from the main x86 CPU in my libreboot X60s, can't directly access any data outside of the physical miniPCI board, and only interfaces to the rest of computer via open-source x86 driver code on the main CPU, this embedded ROM code controlling the embedded RISC processor is however still proprietary firmware. This is the same deal with the microcontrollers inside the HDD/SDD and graphics chipset, which all have proprietary embedded firmware which is interfaced with by the opensource x86 drivers. Firmware != driver.