I think that's probably a fair point.... Doesn't seem like it changes any of the legal analysis though.

You can't disobey a search warrant because it would be bad for business or because you want to protect the target.

I'm not sure it makes much of a legal difference, although maybe it might be a more accurate description of Lavabit's viewpoint. But as the article points out, a business model or ideology isn't a basis to challenge court orders or subpoena power...regardless of what it might be.