If one limits the definition of empathy to the action of understanding or being aware of the feelings, thoughts and experience of another then they certainly are that. However I doubt that they can be really sensitive to and vicariously experience the feelings of another. They can project their own feelings and make good approximations but they don't have the abilities of say an ESE or even an SEI to really connect and be able to put themselves in another's shoes, so to speak. EII is more of a holistic moralist than an empath......

a.k.a. I/O