I vote "no" -- and not just because I'm a perv and it doesn't do anything for me:
I'm not a lawyer, but I think the law would be on my side:
A skimpy bikini top as long as nipples are covered would not be considered porn even though some prudes would say it's in bad taste, so even this -- as much as it pushes the, er, envelope -- isn't porn.
Further anectdotal evidence would be that I would bet if you took a jpeg of that photo to a photo lab, they would print it for you without question. In fact, one time when I picked up some "action" photos, the guy told me he shouldn't have printed them but since I was a regular customer he did it anyway. But he told me "Nudes are OK, even T&A and bush, as long as they're not closeups and absolutely no penetration anywhere." So I've always gone by that rule of, er, thumb. :+thumbs-2