No, that logic is ... incomplete.
Assume the case where the bots are completely incompetant (bots fold every action). Everybody can beat the bots with the same EV. There is no skill involved in that. This case demonstrates that the worse the bots play the less of a game of skill it becomes. It also, arguably, demonstrates that it's in the business's best interest to have bots that play poorly.
99% percent of us 2+2 will quickly master the bot, and just go broke to the rake. The only chance for skill are the people that haven't played long enough to learn (which play money should facilitate), but I tell ya, they'll learn how to be a bot a lot quicker than they can learn how to play poker.
My point is, it will require less skill that regular poker. Instead of hiring a lawyer, try a mathematician maybe
-- and that mathematician would laugh at your implication of 90 hand being relevant. The vast majority of (real-) poker players on the Internet have played more than 90 hands.
I don't mind the presentation of a new game at all, I like considering new games. I just see no grounds for legality of this, and I hate salesmen that misrepresent facts. I like informed consumers that know that two people of equal skill go broke to the rake (or whatever you're calling your service fees). And it will be much easier for all players reach the skill cap against a bot than it would be against a human.
Have fun!