[read_if_gay_]

> I was not responding to an accusation or difficult question.

You're arguing based on technical details of the particular definition you chose here.

If I were to say well, ICE is indeed terrible, but innocent dogs in your local animal shelter are being abused and suffering and you can easily do something about it by adopting one - would you say that's not whataboutism because I was not responding to an accusation or difficult question?

I think this kind of statement captures the meaning of whataboutism perfectly.