If they do agree with you that the paragraph you pasted is their end-to-end definition of "controlled," that means they haven't yet incorporated these other controls into their definition, and they definitely still can and should.
There's no singular time limit or definite requirement to define such things in this case, and IA have engaged lots of controls, from HTTPS and authentication on up to content-level media and time controls.
Sure, they can change their position. But A) I can't go off of what is potentially in some stranger's head and B) they would be redefining the term.
[0] https://controlleddigitallending.org/whitepaper
edit: I hear where you are coming from though. I agree it's got some "control", so you don't like the term "uncontrolled". But I think we probably agree that it isn't "controlled digital lending" even if it is "controlled" to some extent.
> Essentially, CDL must maintain an “owned to loaned” ratio. Circulation in any format is controlled so that only one user can use any given copy at a time, for a limited time. Further, CDL systems generally employ appropriate technical measures to prevent users from retaining a permanent copy or distributing additional copies.
So what they are doing definitely is not "controlled digital lending", by their own definition. At best, it's semi-controlled, but the real essence of the "control" is the number of copies, so "uncontrolled" seems fair.