IMO: Sure, Librem is running Linux. But that's not so much a positive as its just not a negative. Still missing OpenPGP card, no anti-interdiction services, absolutely no hardening. I've been waiting for years, still missing /major/ app support + now I have to pay for that too.
The distinction isn't really GNU because if a distribution uses musl instead of glibc, Clang / LLD / LLVM binary utilities instead of GCC and binutils, etc. it isn't GNU anymore but could still be a traditional desktop distribution with that approach to package management, etc.