My opinion is that it is not...the neckline is too steep and the shoulders don't match up. but if it were...the neckline has been broken signaling that it is a H&S and you would expect prices to fall to the 360 to 408 level.

If we don't get some kind of knee jerk high and this recent low is taken out then you will have a cycle inversion and you would look for the next turn date for a low.