Sure, you can note that, and that's helpful, but other than in the strict legal sense, many coupon code sites do engage in other forms of coupon stuffing. For example, many display fake coupons which don't exist or which they know are expired, and which you must click to reveal. Upon clicking, the target site opens in a new window, and a cookie is dropped. The user was already buying the product anyway, and perhaps another affiliate was set to get the referral commission, but now this accidental popup has stolen it for the coupon site, and there's no coupon to be found. No value delivered for merchant or customer, but the coupon site makes money.

There's a lot of forms of cookie stuffing that are legal, or at least grey, and still seem to me like cookie stuffing, even though they aren't standard, clear-cut, illegal cookie stuffing fraud.