I suppose it is... But, I would more typically describe PWM as a means of limiting apparent output to a percentage of fully on. As an example, with an LED: If the modulation is fast enough that the LED appears less than 100% bright it would be (in my mind) PWM; if the modulation was slow enough that the LED appeared full output, I would call that "blinking". I'm sure that there are a dozen issues with my definition/ description, but its what first comes to mind as how I'd differentiate.
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