pitch angles an aircraft would be unable to maintain speed, thus any execution of such angles is inherently classified as an aerobatic manoeuvre.
Your earlier definition would mean any "converting of excess speed to height" is aerobatic. If you enter a climb from cruise speed, set a higher than sustainable attitude to bleed the speed back to best rate, you are doing aerobatics??????
The real word in that reg to examine is "abrupt" (in relation to an abrupt change of airspeed). Mainly because I'll bet my left one.. [well, actually no, maybe a beer] that Grollo didn't get the KingAir going 45 degrees nose up.