And you still end up with cheesy unit bearings, limited and expensive high steer options, and no locking hubs.
The majority of jeepers never get true high steer nor locking hubs and are doing fine out having fun on pretty tough trails. The unit bearings are not so bad, they hold up reasonably well as long as the tires don't stick out too far. I know several guys who wheel JKs with 37s and they are not replacing unit bearings all the time. Locking hubs break too, the most extreme builds don't use them.
It's kind of hard to specify the ultimate D44. Some ground rules would need to be set down: budget, need for custom fab, whether or not to allow aftermarket parts, what vehicle it will go into, etc.
The main thing that allows the JK to run 37s is the stronger u-joints, which is what most often breaks first on all previous D44s. A close second is that the R&P is stronger. These are things that JK owners will find very hard to give up. They would probably get D60s before going with an earlier D44.