Is it, though? Naming all your villains with anagrams is clever? Or is it... a bit dumb?
Why would they do that? Darth Vader isn't called "MillFal Conellium" for good reasons. It makes no sense. TRD pulled the same trick with Professor Yana ('You Are Not Alone') -- why would the Master call himself an acronym of a thing that an alien said to the Doctor 11 episode ago? Is that clever? Is that a "plot*?
I dunno. I think the more times RTD does this same thing, the less convincing it is. 'Bad Wolf' still makes no sense, for the exact same reason. He confuses sprinkled wordplay with plot.