One of the alleged selling points of a hedge fund is that their short-selling makes them outperform during market downturns. So it's a little odd that Buffett stipulated just returns, rather than returns adjusted for some measure of risk (if I had something that returned .5% less than the market on days when market was doing better than average, and .5% more than the market when it did worse than average, this would be a better thing to own than just a market index, even though it gets exactly the same average return -- because it's giving me extra money right when I'd want to buy other things, in exchange for giving me less money at times when I'd prefer to sell).