If there are potential "shortcomings in the data," then you shouldn't print a misleading title: "Survey Shows Heart Device Aids Men More Than Women." Rather, a better title would have been, "More Data are Needed to Understand the Effectiveness of Defibrillators in Women." Do we really want to withhold defibrillators from women on the basis of such a retrospective literature meta-analysis?
But then, it's the New York Times.
A much better review, including a comment on the study in question by yours truly and fellow EP blogger Dr. Rich Fogoros, can be found over at Larry Husten's Cardiobrief blog.