Read Justice Breyer’s comments on Noel Canning:
“The majority explained that intrasession breaks and adjournments lasting only 3-10 days are presumptively too short”
The current Senate break is exactly 10 days. So the time frame is still too short for a recess appointment to be made, the recess would have to exceed 10 days.
Canning decision: “if a Senate recess is so short that it does not require the consent of the House, it is too short to trigger the Recess Appointments Clause. And a recess lasting less than 10 days is presumptively too short as well.”
Since 10 days is more than “less than 10”, it’s a recess.