As one who worked on them from the early years (1970s), I can say you are all wet. What you omit is the "weapon" aspect. You are just playing techno-lawyer, not knowing the subject at all. Originally, it referred to laser weapons and particle-beam weapons, then expanded to microwave weapons. Otherwise, you get down to saying a ring flashlight is a DEW, which it could never be.
Don't be absurd. The term DEW was coined originally to denote systems that could produce lethal physical effects.
A laser is nothing but directed energy into a beam. Just because it's a low power version doesn't mean it isn't technically a DEW...
A bb gun may be a low power version, but it's still a gun...
As one who worked on them from the early years (1970s), I can say you are all wet. What you omit is the "weapon" aspect. You are just playing techno-lawyer, not knowing the subject at all. Originally, it referred to laser weapons and particle-beam weapons, then expanded to microwave weapons. Otherwise, you get down to saying a ring flashlight is a DEW, which it could never be.