Fair. But..
At the height of the Gulags, the Soviet Union had 1.5 million people in prison. The US currently has 1.9 million people in prison and jails. Most of those people in US jails, are innocent.
The state tortures and and murders inmates in US prisons too. The excess mortality of Black US folk due to racism, is about 1.6 million people a year.
https://pmc.ncbi.nlm.nih.gov/articles/PMC10189563/
Saying "That's Whataboutism!" is the US deflecting valid criticism of its empire too.