no, because the notes are external content not generated by the relays, the relays cannot be trusted ever, the client needs to verify everything. you're advocating for clients to "just trust me bro" which is completely wrong. the practice of displaying a single integer count is the problem, and clients downloading tons of events just for that are the problem. anyway, there's a COUNT nip since a long time ago that I helped shape precisely to unburden relays from this bad practice.