I wouldn't say it's lazy journalism, but it's definitely the work of a journalist who's not well-travelled.
The European ski market dwarfs the NA market. And, many of the resorts in the Alps developed from existing towns, so you get places like Engelberg and Alagna, which were founded in the 12th and 13th centuries, respectively, and still have cobbled streets and centuries-old buildings right up next to a ski lift that takes you into some of the best terrain in the world. So, to label this list as the top 25 in the world and then give the largest market in the world only 1/5 of the resorts is just comical. (And keep in mind this is coming from an American.)
It would be like a Japanese sports writer publishing an article on the top 25 baseball players of all time and only listing 5 Americans and 1 Latin American.