> (k) Digital device. (Previously defined as a computing device). An unintentional radiator (device or system) that generates and uses timing signals or pulses at a rate in excess of 9,000 pulses (cycles) per second and uses digital techniques; ...
https://www.govinfo.gov/content/pkg/CFR-2009-title47-vol1/pd...
This has Wi-Fi, so it's an intentional radiator, so it's not a digital device. I believe this product would be technically noncompliant if not certified, though lots of stuff like this gets sold and I've never heard of any enforcement action.
Their best counterargument would be that it's a component and not a self-contained product. That seems true for many dev boards but not particularly true for this one. Since the practical risk of interference is extremely low, I'd guess the FCC is happy to leave this grey for now.