Maybe? That was my point. The arbitrariness of the DMAs definition of gatekeeper. How is Spotify not a "online intermediation service"?
(2) ‘online intermediation services’ means services which meet all of the following requirements:
(a) they constitute information society services within the meaning of point (b) of Article 1(1) of Directive (EU) 2015/1535 of the European Parliament and of the Council (12);(b) they allow business users to offer goods or services to consumers, with a view to facilitating the initiating of direct transactions between those business users and consumers, irrespective of where those transactions are ultimately concluded;(c) they are provided to business users on the basis of contractual relationships between the provider of those services and business users which offer goods or services to consumers;
I don't think it qualifies but I see how it can be interpreted differently. I do agree there is a level of arbitrariness in the DMA, but that's also expected. Apple itself is leveraging different interpretations of the DMA to impose rules that others argue are a violation.
I think the DMA will need years to fully mature and that will be in part through court cases that will establish which interpretation is "correct", in part through amendments.