Yeah, pretty much.
The backlash on this one always seemed sort of weird to me. It's Eli Roth doing Death Wish for god's sake. The guy's about as base & disgusting & no-redeeming-value as it gets, he's a director equivalent of a shock-jock.
And it's friggin' Death Wish. The Bronson ones were all pretty unacceptable & crass too - the original less so, was a better movie, but they're all pretty guilty of the same criticisms here.
If it's ridiculous, dumb, hyper-violent Roth stuff, whatever. I won't be seeing it as I hate his stuff, but if it's schlocky entertaining in the way his other work is, not really sure what the problem is. So this particular protagonist goes all vigilante with a gun - not sure that's any worse than all the torture in all his other stuff, it's all pretty awful.
He has to know he'll be torn to shreds over this though. I sort of suspect that's kind of the point, Eli just messing with people and trying to create some outrage for his own amusement.
Which, whatever. He wouldn't be the first.