ChatGPT cannot be a Chinese Room because it doesn't have the storage space to create a look-up table for the answers.
The main idea behind the Chinese Room is that the person doing the answering has no clue what the symbols mean. However, the room is organized in an "intelligent" way, such that the room + person creates a coherent response.
My question to you is: what/who organizes the Chinese Room such that the man inside can provide decent answers to a language he doesn't understand?
Then, the follow-up: Is the organizer of the Chinese Room intelligent? Do they understand Chinese?
I think in this piece you're conflating ChatGPT with just the man in the Chinese Room, when really the training process that ChatGPT goes through also needed to organize the room itself.
I could be wrong, however. What are your thoughts?