A recall is about the issue, not how it's resolved. A recall means there are some serious security flaws that needs fixing. Even if they can be fixed OTA, they're still a flaw, and Tesla has had many of those.
Couldn't agree more. Recall means "sufficiently dangerous to need to recall the vehicle to the manufacturer" - yes, in the modern world it can be fixed OTA, but it's still dangerous enough to require a mass fix to a fast-moving death machine.