Versus Zen 2 of course, but likely not Zen 3. Comet Lake is nothing new.
Rocket Lake vs Zen 3 should be interesting, even with Rocket Lake on 14nm.
To be fair to Intel I'm amazed they are still hanging on with 14nm. The question is when they can't rely on clock speed will they be able to compete? It looks highly likely they will lose speed dropping to 10 or 7nm. That will be the real test to see just how good their engineers are.