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> it may get more meaningful for whatever subset of autos that didn't/can't receive the OTA update

I know that for my old ICE car, they keep track of what recalls I apply. I'm usually notified multiple times, when there's recalls.

I suspect that lawyers are why they do it. If your brakes don't work, and you run over a kid, whether or not it was a known recall, and, whether or not you applied it, will likely have a lot to do with how the legal process works out.