Please, do the math. On the N900 (with a 1/2.5" sensor) it would become an issue at ~f/4 and above. The N900, however, has f/2.8 optics, so it's within that limit even with TWICE the pixels mentioned on the site.
Efficiency factor of what ? You can't do a blanket statement like that, when different sensor technologies result in vastly different signal to noise characteristics, and noise itself is a mixture of at least a dozen different factors, thermal noise is just one of which.