That's hardly a "factual error". I can email an mp3 to my friend and have them play it. I can't do the same with a DRM'd song. Is that not harder? Instead I have to make extra efforts to strip the DRM or find a non-DRM'd version elsewhere. For non-technical users, it might actually be "hard" to pirate DRM'd content.
While the article could/should have taken care to make the subtle point that you allude to, I find it's phrasing less disingenuous than yours.