I think this is unlikely, as the format of the data in these records is quite likely the packet format on the air.
It appears to have changed a little from the specification from 2008 (what was post here at least), but not a whole lot.

I would not be surprised if these records are just packet dumps. This is consistent with the story of later on finding out what you can do with them.
Also, I wouldn't want to release their specification if I were to send them on air aswell. Encryption over the air was in 2008 not very complicated (and the processor used has little room for
complex encryption), so revealing this format (and thus the packet format on the air) again opens up the market for protocol-compatible devices. You could just brute-force the encryption using a
regular PC.

Disclaimer: this is all guessing from what I could read from the data. I haven't actually decoded these records. And I'm not sure I would want to, if it means Flarm will have to change formats
again.