That seems true, but only for open source projects. Why would it be hard for closed source projects (where github makes all their money) to move away?
I have been thinking, though, that I don't like the workflow associated with commenting out of band. I would really prefer that people comment by making a branch and modifying my PR (either with code comments or just fixing the problems directly). If I knew how to do that efficiently, I probably would have almost no attachment left to GH.