Collecting these is my thing and finding the errors is great fun. Could be but, as you and Chris both say, the jury is out until another/better specimen turns up.
Something I would draw your attention to though is the upright bar of both the disputed first L and that of the second. Compare these with that of the E, which is much thicker. If the first L was an E wouldn't the uprights be similar? Obviously, a blocked die might account for the difference, but it is something worth considering.
Either way, on the visual evidence as it stands, were you to describe it as 'GIVEIELMVS' I don't think anyone would object.