Wouldn't a properly formed DMCA complaint in this case be one of the few times you could commit perjury with one?

There's no way they have any good faith belief they own the copyright to (or are authorized by its holder to act in their stead about) the material explicitly named.

I'm just going to assume that their lawyer is smart enough to not have filed a DMCA notice, as such, and just send a thuggish letter instead.