Maybe it's a trickery of language. Apple said they "supported Exchange" so you could read your email. There was never any claim they supported encryption on the client. Maybe a lot of businesses assumed they did.
Well yeah, but does that really mean anything? The PalmPre 'claims' to be an iPod so it can work with iTunes. Is anyone saying Palm is engaging in false marketing because of that?
Because the author of the article implies that Apple lied in it's marketing of the iPhone because it didn't actually support encryption. There are two issues here that the article mixes.
1) What Apple says the phone supported via product literature, aka marketing.
2) What the iPhone software does to implement exchange support.
Misrepresenting #1 is a crime that the FTC or some government body could fine them for. #2 on the other hand companies do all of the time to make their devices work with proprietary software. This article is implying a marketing lie while describing what is a software compatibility hack or perhaps an honest bug. Either way saying "I simply can't count on Apple to do the right thing." is way melodramatic.
Actually, their software made exactly that claim, and falsely, if I read the article correctly.