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.
> For the future, SpaceX plans on expanding its laser system so that it can be ported and installed on third-party satellites. The company has also explored beaming the satellite lasers directly to terminals on the Earth’s surface to deliver data.
The customer terminals will likely never connect through lasers (because a laser can only point in one direction at a time), but moving the ground station uplink to a laser link sounds very beneficial.