In this note, we show that, for all $n\ge 2$, the number of distinct rooted binary phylogenetic $X$-trees displayed by a binary tree-child network $\mathcal{N}$ on $X$ with $n$ leaves is at most $2^{n-1}-1$ and that this upper bound is sharp. Furthermore, if $\mathcal{N}$ displays exactly $2^{n-1}-1$ such trees, then exactly one rooted binary phylogenetic $X$-tree is displayed twice, and this tree can be canonically found by iteratively replacing a reticulated cherry with a cherry.