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.
Sounds very cool that cross-plane links are doable, even if they have predictable complications compared to in-plane.
I would have thought that someone would make a big deal (have a press release, e.g.) out of successfully establishing cross-plane links, but maybe it just doesn't seem that impressive to people who already have good enough precise predictive ephemerides or satellite states to make those links in the first place.