767 LoC of code including comments describing the grammar. Strip out the comments and you're already do to 600. Move opening brackets and a other very few steps, and you get it down to 560. Getting this below 500 lines should be fairly trivial.
So if your comparison is the completely unreadable otcc, then I'd say yes, this qualifies.
So if your comparison is the completely unreadable otcc, then I'd say yes, this qualifies.