Personally, I wouldn't call it as LAL. But this area is too specific and personal, since there is no strict definition what is a LAL and what is not. In general, when we speak about any pattern we have to understand its market mechanics. The point is that such tops as we have - do not correspond to normal DRPO action. DRPO is exhausting pattern and second top is capitulation of bulls - last challenge before collapse. That's why it should be significant. From that perspective - this is not a LAL. But if we have, say, thrust with small penetration of 3x3 or closes not strictly above-below-above, too much consolidation between tops, compares to the thrust. Something of that sort - this could be LAL.
But that is just common observation, each case is unique.
Thanks, Sive!