I think the part of this that resonates as most true to me is how this reframes learning in a way that tracks truth more closely. It's not all the time, 100% of the time, it's in fits and starts, its opportunistic, and there are long intervals that are not active learning.

But the big part where I would phrase things differently is in the insistence that play in and of itself is not a form of learning. It certainly is, or certainly can be, and while you're right that it's something other than Borg-like accumulation I think there's still learning happening there.