I guess. I mean they're both incredibly small niche vehicle volumes that it seems a bit strange to split hairs on which model.
Teslas aren't cheap by any means, but there are a lot of people who could afford something in the 70-85D range but not a P85D.
On the other hand, the only real difference between a P85D and an 85D is acceleration, so I don't think there's much need to do a separate review just for the lower-end cars.