Apple's Letter Passing The FAIR Test

After reading Parker's post, I agree with most of his argument until his opinion on of the letter passing the FAIR test. Although the letter does help Apple's credibility in the case, I do not think the letter would pass the FAIR test.
The letter only shows Apple's point of view on the issue and does not take into consideration why the European Commission ruled the way they did. The only facts presented help Apple's case.
Also while some of Apple's motives are clear with releasing the letter, the main reason for his letter is to save face in the public eye. As we do not know all the facts of the case, it makes me wonder if they are hiding any information or are leaving certain facts out.
It could certainly be a possibility seeing as how the