I hate to enter this discussion, but learning based on a small number of examples is called few-shot learning, and is something that GPT-3 could already do. It was considered a major breakthrough at the time. The fact that we call gradient descent "learning" doesn't mean that what happens with a well-placed prompt is not "learning" in the colloquial sense. Try it: you can teach today's frontier reasoner models to do fairly complex domain-specific tasks with light guidance and a few examples. It's what prompt engineering is about. I think you might be making a distinction on the complexity of the tasks, which is totally fine, but needs to be spelled out more precisely IMO.
Are you talking about teaching in the context window or fine tuning?
If it is the context window, then you are limited to the size of said window and everything is lost on the next run.
Learning is memory, what you are describing is an llm being the main character in the movie Momento, I.e. no longterm memories past what was trained in the last training run.
There's really no defensible way to call one "learning" and the other not. You can carry a half-full context window (aka prompt) with you at all times. Maybe you can't learn many things at once this way (though you might be surprised what knowledge can be densely stored in 1m tokens), but it definitely fits the GP's definition of (1) real-time and (2) based on a few examples.