Because the older meaning of "virtual reality" is similar in meaning to "cyberspace" and not just a euphemism for "3D immersive display". It meant exactly what the phrase implied -- a virtual reality. Displays like the Oculus are a way to experience a virtual reality, but are not full immersion (eg, tactile feedback) and are not the only way we could theoretically experience one. Things like advanced cockpit or vehicle simulators arguably count. (Think things with a mocked up vehicle interior, but windows are replaced by monitors. Often, these are mounted on systems that provide motion feedback.)
That meaning has largely been transitioned to the term "virtual world" (eg, in Second Life's marketing materials) because of the terminology collision around 3D headsets.
I personally think this is an abuse of marketing that destroyed a useful term to a reductionist view because they wanted to co-opt the interest and goodwill around the long history of literature on the original meaning. Other people feel differently.
In your case, you're being downvoted because you're insisting people only use the reductive new meaning of the term, when it was used perfectly sensibly in the older style in the title. (As it would apply, in calling Second Life "VR", since it's a "virtual reality".)
This is typical for technology reporting.
edit: Someone want to tell me why this comment is getting hammered?
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