For some images, there is dialog, so the test could be transferred directly (Manga, comic books, etc). But many many images don’t have any text at all, and often only one character.
I think there’s probably some version of ‘the male gaze’ that could be avoided. But maybe someone has a more canonical answer?
I’m not sure that counts, considering which subset of the population is the largest consumer of it. That in and of itself doesn’t make it fail*, but the fact that the makers of it know this and thus might be tailoring it for that audience does kind of make the the whole thing about men.
Basically, we’re just swapping one meaning of intercourse for another.
* in the same way a group of men watching a regular movie that passes the test wouldn’t change that fact.
That, and titties.