That and bots that don't execute javascript would be a problem, yes. Our clients can account for that by comparing their traffic numbers with ours.
(full disclosure: I work at White Ops on the 'botprinting' team)
EDIT:
Its apparently stated here: http://www.marketwired.com/press-release/White-Ops-Secures-7...
"White Ops offers the world's first systematic solution for accurately isolating and eliminating bot-infected traffic. By applying the techniques of Side Channel Analysis across thousands of real-time user session variables, White Ops differentiates between a human and machine-driven request -- regardless of the sophistication of the bot programmer and across the full spectrum of impression and click fraud techniques. This approach is vastly more effective than methods generally employed by legacy fraud detection services, which rely largely on historical data and statistical and predictive analysis to detect bot activity. "
That said, if I had a botnet I'd just figure out what domains belonged to WhiteOPs and null-route them.