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
Where's the love for the Walmart Exclusive Iron Man: Movie Special Issue #1? It came out in September/October of 2008 and features Coulson throughout.
Here's some pics from the Walmart Exclusive Iron Man: Movie Special Issue #1. Ashcan sized, packed in with Wal-Mart copies of the DVD (released around/on 9/30/2008). The story is essentially a Coulson solo story taking place during the first Iron Man film, with Coulson featured as early as p. 2 and named throughout. Here's a couple of pics including the cover.