It depends on who is interpreting the DMCA really.
It criminalizes production and dissemination of technology, devices, or services intended to circumvent measures that control access to copyrighted works (commonly known as digital rights management or DRM). It also criminalizes the act of circumventing an access control, whether or not there is actual infringement of copyright itself.
I know I shouldn’t feed the trolls, but it’s right in the blurb.