Oh yes, I think a good case can be made that it is; but the letter sounded to me like they were saying it is officially considered a cult, not that they were expressing a personal opinion, and that made me wonder if there could be cultural circumstances outside the letter that would make their attitude less nonsensical. I believe the second letter was responding to points that were brought up in the comments to the original letter to Ask a Manager (ie JWs not celebrating holidays, presumably including birthdays).