Sure, but based on the similarities in the Central Semi data sheets, the same die appears to be used interchangeably. So the factors I can imagine is that they select and direct the leakier parts to the TO-220 package, or that the TO-220 package makes a difference (like allowing a higher junction temperature before the chip will self-destruct, or an intrinsically leakier package), or that the MJE is allowed to be exposed to more adverse circuit conditions (and they would have the same leakage in the same circuit). Otherwise, I lack the imagination to conjure up other plausible differences as long as they use the same chip. Or maybe other manufacturers do not use the same chip for both part numbers, and Central decided that using their MPS-A42 chip would not violate the Icbo promises for the MJE-340 (from Motorola since Central is a second source). If I had parts from several companies, I would be even more motivated to open them up and compare.
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