As I understand it, 1996alnl is correct.
SureFire has used the best LEDs it can. As LED technology improves it is possible to obtain sufficient quantities of more efficient and/or higher output LEDs so there has tended to be a base-line from which performance increases.
With regards to SureFire's LuxeonV lights such as the L2, L4, L5, L6, L7 their initial rating was a ball-park one performed quickly to get the rating into the catalogue at the time. It took SureFire some time to resource testing a sufficient quantity of production samples in order to be confident they could increase the rating.
I believe in general terms one can assume SureFire output ratings can have "at least" in front rather than the ratings be considered a maximum possible value.