I disagree with your implicit assertion regarding the common meaning of the term in this context. I believe that the term fraud as commonly used when discussing things in a scientific context has always (for at least my entire life) been taken to refer to knowingly and intentionally falsified research results (also falsified appointments, falsified affiliations, falsified authorships, etc).
> deception in order to get a benefit.
The point being that reckless or negligent conduct is not commonly taken to constitute deception. There's a reason we have different terms for these things.
Sure, you can say "well he exhibited reckless disregard for his professional duties when he opted not to bother reading the citation section that the LLM shat out, and reckless disregard is sufficient to meet the legal bar for fraud, and also the ToS specifically says that you certify that you validated all references manually so bam! two counts of fraud legally speaking" and you wouldn't be wrong but the distinction between "legally fraud" and "fraud as is commonly meant when talking about scientific papers" is essential to effective conversation in this particular instance.
> Just because we're talking about a scientific context does not mean we need to use the scientific-jargon versions of words
The context is essential because (obviously) it affects how people interpret the meaning of your words. A fraudulent submission to a scientific journal has a specific and well understood meaning in common usage.
If you still disagree with me imagine polling a bunch of tenured career researchers about what they would think if they read the statement "X caught submitting a fraudulent paper to journal Y". I can just about guarantee you that none of them are imagining hallucinated citations.