Hi Nick

You're right, but it's still not burning deuterium or anything else, so a "planet" is a reasonable box to put it in. Anthony Whitworth and colleagues developed a model that quite efficiently makes such objects... Brown dwarf formation by gravitational fragmentation of massive, extended protostellar discs ...and also showed, as much as an SPH model can, that nothing much forms via disk instability closer than 40 AU... Can giant planets form by gravitational fragmentation of discs?

Seems like a natural division - planets via core accretion within 40 AU, brown-dwarfs via instability further out - except forming planets via core accretion is yet to jump the hurdle from dust to planetesimals. After that everything works, but the small details are still recalcitrant to theorists efforts!