No
While the wording is perhaps unfortunate, the weapon manages to achieve what is effectively touch AC targeting by virtue of touch AC not really being a thing.
Touch Attacks
Some attacks completely disregard armor, including shields and natural armor—the aggressor need only touch a foe for such an attack to take full effect. In these cases, the attacker makes a touch attack roll (either ranged or melee). When you are the target of a touch attack, your AC doesn’t include any armor bonus, shield bonus, or natural armor bonus. All other modifiers, such as your size modifier, Dexterity modifier, and deflection bonus (if any) apply normally. Some creatures have the ability to make incorporeal touch attacks. These attacks bypass solid objects, such as armor and shields, by passing through them. Incorporeal touch attacks work similarly to normal touch attacks except that they also ignore cover bonuses. Incorporeal touch attacks do not ignore armor bonuses granted by force effects, such as mage armor and bracers of armor.
From this we can see that creatures have only one real armor class, despite the oft-used convention of recording three separate numbers on one's character sheet. A touch attack can be said to target touch AC, but that's just a linguistic shortcut for saying 'armor and shields and maybe other stuff don't work, so the target's AC is lower than it probably normally is', not a completely separate statistic with different rules.
Since the X-laser had the advanced firearm property 'touch', all attacks with the weapon resolve as touch attacks (yes, even pistol whips). The X-Laser's use is an attack, so enemies don't get to add their Armor, Shield, or Natural Armor bonuses to AC when calculating AC for the purpose of resolving those attacks.