Yes! This exactly. This is what I've been thinking. Legal aspect aside, the whole scene was framed like a rape. It calls to question, emotionally speaking, whether genital contact is necessary for an act to be called a rape. Certainly Hotch has been violated. The word "rape" seems to be tripping a lot of people up. I think the point here is that it IS rape, even if Hotch remained fully clothed during it all. So many people (not necessarily here in this comm, I mean in general) have a rigid definition of rape: men can't possibly be raped, men can't be raped by women, women can't rape other women, etc, etc. I think the show is making one question one's definitions and preconceived notions, like it always does.