This action definitely should not qualify as targeting. Remember that the rules do require the targeting aspect which is missing here.
"No player shall target and make forcible contact to the head or neck area"
I've got to agree with Kalle here. Have we lost site of the critical wording that's in multiple places in the book that repeatedly attempts to stress that we have to have two elements together to get the targeting foul:
Targeting
and Making Forcible Contact With the Crown of the Helmet (Rule 9-1-3) and Targeting
and Making Forcible Contact to Head or Neck Area of a Defenseless Player (Rule 9-1-4).
I don't see how a textbook wrap-up tackle where the tackler and receiver go down together can be judged to meet the targeting half of the rule. IMO if this one is targeting because the two facemasks touched then the rule's broken and needs some serious work.
And for the "checklist" guys who want this call to be simple, IMO you're missing the threshold requirement that the initial contact per 9.1.4 (the first half of the rule) qualifies as targeting, before you get to the second half of the rule (the checklist):
0) Did the tackler target the receiver? IMO no.and (if 0 is yes)
1) Defenseless player?
2) Contact to the head/neck area?
3) Forcible contact?