I would think so. The lifter will bleed down to a point, then once the holes are misaligned, it will become a solid lifter, or it might have bottomed out. Also, if the inner body is worn, there will be a lot of bypass between it and the outer body.
This is why one adjusts hydraulic valves with the engine running. This allows the lifter to fill with oil and maintain '0' lash.
There is a time limit on lifter bleed down. There is a tool with a weighted head and a plunger. One sets the lifter into its future oil, pump it up with a pushrod to fill it. Then place it underneath this weight and time it. If the lifter did not meet this time requirement, then, the lifter is determined bad, replace it. Haven't seen one of these tools in eons.
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