I would be mildly shocked if it was, because (a) the relevant bits of QEMU are under GPL or LGPL, and it doesn't seem very likely that you could get $1.3m investment for a product you'd have to GPL, and (b) if you're interested purely in userspace application translation (and especially if you are happy to restrict to a single guest and single host architecture) then you can almost certainly come up with a better-suited design for that than QEMU (which is rather generalised and focused more on system emulation than userspace).