As far as I know, no court has ever decided something like that but most likely yes. But don't ask me where to draw the line.

Also note that this is no different to other copyrighted works: If you were to describe the shapes of all letter in a copyrighted text that would be a violation just as it would be if you gave a pixel-by-pixel description of a copyrighted photograph.

Continental European law is mostly decided on a "spirit of the law" basis not on a "letter-by-letter basis". So if someone finds a loophole that obviously is one it is automatically covered.