On the one hand, I tend to agree with you. But on the other hand, I think there is a significant nuance - for many users going into recovery mode is beyond what they are comfortable doing with their laptop and so for all intents and purposes a laptop that can only be recovered that way is unrecoverable.

More generally, any issue with a computer can be fixed by a sufficiently skilled and determined user - maybe with some data loss. Even a broken firmware might be fixed by writing a new one, cracking the authentication mechanism, and building a custom rig to flash it to the chip.

It's all a matter of degrees and how much users can be expected to do which makes defining exactly what "bricked" means very difficult.