I'd argue it's still a case of deception. The fact that the patent is poorly titled doesn't change that. If the patent were titled "wheel and axle" but contained its current content, it would still be misleading to say that someone had patented the wheel and axle.

And no, I don't feel like digging through a bunch of anti-patent articles looking for misleading claims. Even if this were the only example, the point would stand that using misleading claims makes it harder to trust the movement.