I argue that a criterion of theoretical equivalence due to Glymour :227–251, 1977) does not capture an important sense in which two theories may be equivalent. I then motivate and state an alternative criterion that does capture the sense of equivalence I have in mind. The principal claim of the paper is that relative to this second criterion, the answer to the question posed in the title is “yes”, at least on one natural understanding of Newtonian gravitation.