IBM punch card = DMCA circumvention device?

Larry J. Blunk asks:

Can an IBM punch card qualify as a circumvention device under the DMCA? I've translated Tom Murphy's "embed" program from C to a short Perl script.
Agfa Monotype claims that embed violates the anti-circumvention provisions of the DCMA (the programs clears the 16-bit
"embedding" flags field of TrueType files). At 76 characters, this script will neatly fit on an old IBM punch card. Given
that punch cards are machine readable, would this qualify as a DMCA circumvention device?

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