I think you can
only make a case for the game being pay to win.
"Once you've spent a bit of money on some cards" means I can be the greatest player of all time, but if I haven't paid for the cards, I can't win. They don't just give you these cards for being good. You can't find them scattered around the environment. You have to buy them, somehow.
What is pay to win in your mind? The phrase generally means "no matter how good you are, if you are unable to buy a certain set of cards you can't truly compete in the meta". There are more or less expensive decks, but typically the cheapest of the best decks in any format cost $50+
Edit- This is for constructed formats. Obviously sealed is more of a pure skill, low cost format.