This would not count as a false proxy however. The problem in software is, it is very hard to construct meaningful proxy metrics. Most of the time it ends up being tangential to value.
The value in tracking false proxies like lines of code, accrues to the tracker, not the customer, business or anyone else. The tracker is able to extract value from the business, essentially by tricking it (and themselves) into believing that such metrics are valuable. It isn't a good use of time in my opinion, but probably a low stress / chill occupation if that is your objective.
This would not count as a false proxy however. The problem in software is, it is very hard to construct meaningful proxy metrics. Most of the time it ends up being tangential to value.