NIP-39 came after NIP-05, that is the only reason it isn’t one
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Then nip-39 should have extended or deprecated nip-05, which is not the case. It is a simple birds of a feather issue. We are talking about nip-05 and the associated design, nip-39 is a different design not even mentioning nip-05 or referencing it as a use case.
Nip-05 should be extended to include this, nip-39 is not suitable as it adds unnecessary complexity to a simple task. The only reason to suggest it is to push off an idea that might have consequences to your personal take.