People are taking this too seriously. Buffett probably sees Jobs as a rival (perhaps not a direct one) and it is instinctive to highlight the flaws in your com

People are taking this too seriously. Buffett probably sees Jobs as a rival (perhaps not a direct one) and it is instinctive to highlight the flaws in your competitors. Furthermore, I don't know if Buffett stands to gain or lose depending on Apple's share price but he is probably more concerned with the general principle of disclosure. The use of "material fact" was probably used by Buffett to make it clear that there is an obligation (at least ethically and potentially legally) to disclose this sort of information (i.e. that Jobs was putting himself at a much greater risk (transplant) than implied and disclosed).