Cross-plane optical links would have a trickier tracking problem.
While there's no explicit mention of same-plane vs cross-plane optical links, I assume that the first time people have a public cross-plane optical link, they will make a big deal out of it. :)
The article also mentions that SpaceX would need to do further study before using laser links between satellites and ground stations-- this kind of optical link would require both more angular tracking and probably atmospheric correction as well.
“ Cross-seam inter-satellite link hand-offs would have to happen very rapidly and cope with large Doppler shifts; therefore, Iridium supports inter-satellite links only between satellites orbiting in the same direction.”
https://en.m.wikipedia.org/wiki/Iridium_satellite_constellat...
The wikipedia link above explains it well:
""" Orbital velocity of the satellites is approximately 27,000 km/h (17,000 mph). Satellites communicate with neighboring satellites via Ka band inter-satellite links. Each satellite can have four inter-satellite links: one each to neighbors fore and aft in the same orbital plane, and one each to satellites in neighboring planes to either side. The satellites orbit from pole to same pole with an orbital period of roughly 100 minutes.[8] This design means that there is excellent satellite visibility and service coverage especially at the North and South poles. The over-the-pole orbital design produces "seams" where satellites in counter-rotating planes next to one another are traveling in opposite directions. Cross-seam inter-satellite link hand-offs would have to happen very rapidly and cope with large Doppler shifts; therefore, Iridium supports inter-satellite links only between satellites orbiting in the same direction. """
The 'seams' have interesting implications for latency when I was working on Global Data Broadcast.