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Not really. Nebula creates a layer-3 network[1]. Rayfish is built upon Iroh which is a layer-7 network.

[1]: https://nebula.defined.net/docs/#technical-details

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But ... Rayfish creates a layer 3 network too. It assigns IP addresses to each node. I don't really see why it matters from this point of view whether it uses Iroh or something else to provide its backhaul. That's like saying Wireguard works at layer 4 because it uses UDP. The whole point of VPNs is to offer some kind of tunneling over higher level protocols.
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