I don't see where is the problem?
The problem is, or was, that you are, or were, claiming that HN39 was wrong to suggest that the aircraft would pitch up with neutral sidestick in certain circumstances.
If you want to say that it is merely a 'mode' of the normal law then fine, do so. But for me it would be truer to say that it is another control law which can only be accessed from normal law. In practice there is no similarity between the two things. In normal law stick movement commands 'g' in alphaprotect it commands AoA; in normal law there is a C* feedback, in alphaprotect there is no such thing.