"so it hasn't completely been freeloading."

That's Clang/LLVM compiler that gets them off GCC's GPL codebase. It also allows them to keep more extensions proprietary if they choose. It's been beneficial to the OSS community but I'd say it's barely altruistic. An exception rather than the rule.

" The "how Apple treated BSD" phrasing sounds like there is more active bad treatment rather than not contributing enough"

Helps to remember that it's how a lack of contributions is commonly phrased. Freeloading is probably the dominant model for both users and companies far as FOSS. It's just how they word the gripe. I agree they should probably use clearer phrasing for others not deep into this subject matter.