For what it's worth...
When I discussed 3DMark03 with NVIDIA, their main concern was with the method games 2 and 3 used to calculate shadows. They documented the program code used in 3DMark03 and discussed its inefficiency.
They also provide examples of graphics artifacts that occurred as a result of the shadow algorithm.
Since I'm not a developer, I can't comment on if the code is inefficient or not. But it is documented.
There was no discussion concerning pixel shaders.