Yeah, but it was tested against a similarly priced R9 285 running at higher clock speeds from the same manufacturer. Given the 285's 256-bit vs the 960's 128-bit memory bus, I don't think the comparison was unfair.
Well .. it would depend on if the 285 was the target and only thing that would be 100% fair would be for Nvidia to release the 960 without knowing the 285 performance ..as they have took there time tweaking the card and driver to be faster then the 285..
but I feel the 285 was just bate for Nvidia as the R9-370 has yet to be seen.. and the unfair part starts over as they now know what the 370 has to beat.