Technically true but practically irrelevant in terms of consumer impact. The number of Android devices in the US without Google services is easily a rounding error. ~100% of the Android handsets in the US have Google's software preinstalled.
This is a fair point, yet I don't think it's good to disparage what's technically true here.
There are people attempting to take advantage of the fact that Android remains free and open source, and they need support. Perhaps I should have included that in my comment above.
It's not obvious to me that a legal solution would be better.
I think Google's bundled services cements their grip on AOSP more than it supports it being independent. All Android handset OEMs basically have no choice to install Google services because AOSP isn't mass marketable on its own, and nobody can really compete with Google's combination of Play/Gmail/YouTube/Chrome/search. Once you have a Google account, you get funneled into these other services, and it makes it difficult for any other services to gain traction. If we want AOSP to truly be free, then it has to be useable outside of the Google ecosystem.
Android is like a club with free drinks, but Google Services are the $150 cover charge.
