Sure, but then the better US comparison includes things like the Chicago/NYC/Boston/DC/Atlanta train systems, which I'd imagine a decent number of folks in those cities take more than 31 times a year. Heck, I think I've taken more than 31 MTA rides per year and I don't even live in NYC.
City train systems are not offered by Deutsche Bahn AG, but by local city carriers, so they are not part of that statistic. E.g. Munich is mostly run by MVG and had 596 million passengers in 2018 [1], which aren't included in the numbers above. DB only runs the S-Bahn in Munich.
But yes, the 2600m DB passengers probably mixes long distance and short distance service to some degree.
Its more than ICE trains not more than the whole of DB. Its 100m ICE trips per year but 2600m DB trips per year in 2019 (c. 31 per capita per year)
https://www.statista.com/statistics/936254/deutsche-bahn-pas...