[trogdor]

Because it is a recall, and your suggested headline would be misleading.

Tesla routinely pushes software updates. This one, however, is different. It’s the result of a multi-year NHTSA investigation, and it’s legally a recall.

The National Traffic and Motor Vehicle Safety Act gives NHTSA the authority to require manufacturers to recall vehicles that have safety-related defects. Just because this recall is being addressed through an OTA software update doesn’t make it not a recall.