I think this is a legitimate question, and a reflection of how the NHTSA needs to adjust their wording for modern car architectures.

It's technically a recall, but it's fixed with an OTA update. But the fact that any "defect" that can be fixed with an OTA update is called a "recall" is confusing to consumers and contributes to media sensationalism.

There absolutely needs to be a process overseen by regulators for car manufacturers to address software-based defects, but the name would benefit from being changed to reflect that it can be done without physically recalling the vehicle to the dealer.