I believe the referenced story qualifies under that metric. In part, it's revisionist history -- and thereby anti-mainstream. And I very much doubt that the TMZ crowd would even be interested in parsing stories told from such a business/technical perspective. But that's neither here nor there.

In all actuality, I do sympathize with the rational for your proposed metric. I'm just pointing out that the nuance and angle of a story can push something distinctly into that category in cases where simply reading the title might lead one to have a "Not HN!" spasm.