I think this will become a pedantic argument, but without defining loophole, we can’t say they exist or don’t.

Presumably a law is written with some intent. When that intent or spirit is broken because of poor construction or poor foresight in the text of a law, a lot of people call that a loophole. I think it is a fair definition.

along this line of thought, using a library written for one use case for a separate use case could pedantically be considered a 'hack'.

I simply share the opinion that the people writting tbe laws should recieve the heat, not those doing what they are legally allowed to