That's a good question. I asked it myself just recently, and couldn't get a definitive answer. But people seem to agree that a game qualifies if you can press a key to start, without reading any menu, and have fun in there even if you can't read any text that may be present. If you do need to read in order to get very far, or win, or simply to use more advanced moves, then it's ambiguous; use your best judgement. But if it's just "use the arrow keys and space (or the mouse) and go pew-pew at baddies", the textless label probably applies even if technically there's some text in there. It's very hard to avoid all of it.