That’s nonsensical, IMO. Software updates should not be considered recalls at all. Unless it’s a critical safety issue that makes the vehicle unusable.
Awesome. Let's do that, right after we stop calling "place this sticker, which contains a warning about materials in the seatbelt tensioner system, on page 234 of your owner's manual" a recall, too.
Past Tesla recalls addressed by OTA updates include fixes for braking, steering, headlights, tire pressure monitoring, collision avoidance, etc...
https://www.cars.com/research/tesla/recalls/