No, because the 70% spell damage is a 10.7% increase over the 650%, with that much “base” spell damage the 70% spell damage affix would be more effective.
1000 * 7.5 * 2.5 = 18,750
1000 * 8.2 * 2.5 = 20,500
1000 * 7.5 * 1.09 * 2.5 = 20,437.5
You took the 20,500 (720% spell damage figure) & then added the 9% pen.
Adding an extra layer (the crit multi) into the calculation doesn’t change which gives more, it just makes both numbers bigger.