Right, but while he still had money in Seesmic, there was a huge Seesmic widget on every page on TechCrunch.
I doubt even the most honest reporter can reliably cover a market he's invested in. Actual journalists seem to agree: http://www.nytco.com/press/ethics.html#avoiding
(Unfortunately it seems that the people who wrote this ethics code are now taking cues from TC, rather than the other way around)