I see what you mean and understand the confusion. Though I think it is called what it is because it is a distinct Windows subsystem, with various kernel drivers

I see what you mean and understand the confusion. Though I think it is called what it is because it is a distinct Windows subsystem, with various kernel drivers and modules, that are for Linux processes. The substytem is still Windows (using Pico providers and processes), and so it is therefore not a “Linux Subsystem”.