A door-handle follows rules and works entirely rationally, but not many people would consider it intelligent.
Here's another question, is an egg alive? (I mean an egg containing a living embryo in this case)
You have your universe made mostly of rock and ice and cold cold nothing, but nestled inside is conciousness. An egg is a shell of non-living calciferous matter, but it contains
life, life which would not be sustained otherwise.
I suppose you could separate out the bits, this bit is alive and that bit isn't, but if you keep going with that your cutting down to what is or isn't conciousness - then your screwed! You find me a piece of conciousness and I'll give you a squillion pound note!