Yes, since that's Coulson's first 616 appearance, but not his first comic appearance overall. Coulson's first appearance ever in comics is in the non-616 "Iron Man/Incredible Hulk/Nick Fury" one shot in 2009. The timeline of early Agent Coulson appearances seems to go like this:
Iron Man/Incredible Hulk/Nick Fury one shot, Cinematic Universe - February 2009:
Page where he first appears:
Iron Man 2: Agents of S.H.I.E.L.D. one shot, Cinematic Universe, first cover appearance: November 2010
Battle Scars #1, first 616 appearance, although not referred to as Agent Coulson until Battle Scars #6 - November 2011
Sooooo, that's a no?