Sure it is. AI is a computer reacting to its environment to solve a problem. It doesn't necessitate machine learning, neural networks, or what-have-you.
This doesn't have a scoring function or objective function hence is not 'solving' a problem. it's just mimicking a behaviour. There is quite a difference.
Sorry but I don't see any intelligence in this.
It's still AI though.
I always thought that the I in AI stood for Intelligence
AI always seems to be that elusive magical self-conscious computer algorithm, which when revealed to run on actual binary logic is claimed to be "not AI after all"