>>40352477It's more the "why" of those parts being hard.
Those difficulty spikes are like indie game spikes. They come out of nowhere, herald no later increase in difficulty, and the difficulty isn't in some unique strategy or gimmick the boss deploys, or puzzle the boss demand you solve, or fundamental skill the boss is making sure you know how to use, like many difficulty spikes are, they are just randomly much stronger than everything else, and just kinda leave when that's said and done.
>>40352482If you base it entirely on these spikes, sure, it is, but if you base it on the rest of the game, it's easier than gen 4, HGSS, and gen 5. Arguably gen 3, though that's more because hoenn shitmon syndrome during the early game than proper difficulty either. Besides that, gen 3 is piss easy.
If basing the difficulty of a game solely on the hardest part without looking at the duration or frequency of that kind of event is how you do, then cool, you do you.
Outside of that definition though, it really isn't.
B&W2 challenge mode remains the hardest a pokemon game has ever gotten, consistently, throughout the entire run.