Yes, because he was dead. That’s my point.
When Roddenberry decanonized TAS, it meant DC had to alter the art of the first couple issues of their second Star Trek series to change M’ress into a new character, M’yra, and Arex into a character called Fouton (iirc.) so, it did indeed have real-world impact on creators of Star Trek tie-ins.
I'm going to go out on a limb here and suggest the phrase "had to" is an overstatement.
They went along with it in order to keep Roddenberry onside, that's not the same thing. I don't think there's any legal power behind "de canonising" anything. TAS still exists, it can still be broadcast, it can still be referred to.