I think you are basically just making this up. Please point to the study or article or your personal tests that even indicate this is true, let alone prove it.
If, as you say, the iPad overheats when the ambient temperature is 95 degrees fahrenheit then these people actually have a good case and Apple is on the hook for millions in damages.
I don't believe this is true. I think you are just assuming stuff here that isn't actually in evidence.
All he was saying is that there can be a significant difference between ambient temperature and the temperature of an object placed in direct sunlight.