It's not processor op-codes, but sure it's part of the software. You wouldn't say that a set of precomputed weights in a numerical integrator aren't part of the software, would you? Or say that the graphics in a game aren't part of the software?

> a model is not software

When does code become software?

How does that change anything? It doesn't matter if you categorize it as software or not, unwanted is unwanted. And frankly I just flatly disagree, you could certainly make the case that model weights are a form of software.