I mean duh, but also this seems like a fairly weak gotcha. Cookies != Tracking, they can track you just fine without cookies, and they can use cookies without tracking you.
That's probably true, but not what the articles reporting:
> 55 percent of the sites it checked set ad cookies in a user’s browser even if they opted out of tracking
So essentially, it's ignoring user preference directly, not just in spirit.
That's historically been a very prominent purpose of cookies.
Sure it's not exclusively tracking, but it's nonsense to make the assertion that "Cookies != Tracking"
They're not primarily for tracking either.