It's mostly because in the VFX/CG space for ray tracing/path tracing de-noisers, they almost always rely on extra outputs/AOVs of things like 'albedo' (diffuse reflectance), normal / world position, etc, to help guide them in many cases.
So they often can 'cheat' a bit, and know where the edges of things are (because say the object ID AOV changes - minus pixel filtering, which complicates things a bit).
They can also 'cheat' in other ways, by mixing back in some of the diffuse texture detail that the denoiser might have removed from the 'albedo' AOV channel.
Cameras don't really have anything to guide them, so they have to guess. And often, they seem to use very primitive methods like bi-lateral filters (or at least things which look very similar), to try and guide them, but it doesn't work very well.
Portrait cameras on phones can use depth sensors a bit to help if the camera has them, but for things like hair strands, it doesn't really work, and is mostly useful for fake-depth-of-field depth-based blurring.
Fwiw, Topaz -- which I have a license for but essentially never use -- has pretty incredible denoising & upsizing features (for both photo & video), but to get the optimal quality output you offload the processing to their cloud infra (and buy credits from them to pay for it). It's roughly the equivalent of a SWE using a local LLM that's good enough" vs a frontier model that's SOTA but requires a consumption-based subscription.
1: https://blogs.nvidia.com/blog/ai-decoded-ray-reconstruction/
Autoencoders can presumably do this except that it would be operating at levels of patches rather than the entire Moon.
https://news.ycombinator.com/item?id=35107601
It was probably a result of an explicit company charter but such things can happen with modern ML models quite unintentionally.
Bear in mind, a modern flagship phone doesn't just need to take photos - it also needs to record 4k video at 60fps.
Can't go too hard with the ML when you've only got 1/60th of a second to do it.
One day smartphone cameras might get there, but right now, the sensor technology isn't there yet. The problem isn't merely noise. It's that rain and snow are moving about in the scene, which means that the camera can't just do its usual trick of taking multiple exposures.
AI denoisers are nice, but they aren't strictly necessary for ILCs. Even those full-frame cameras without IBIS are able to take pictures of nighttime snow just fine.