Eugene, it's not Netapp-bashing. No company is perfect for everyone and I understand the pros and cons. We bought a filer recently and I would have no hesitation making the same decision again. From that point of view, money talks.
There's really no point in discussing your lab benchmarks if you can't reveal them, or at least reveal the specs you testes against. I'd expect ZFS and so on to be slower than WAFL/ONTAP. That problem is easily solved, as one can easily build a ZFS box with 24 cores and 64GB RAM. That costs about $20,000 which which I guessing is not far away from the list price of a FAS2040 with no disks, a single CPU core and 4GB RAM and some basic block access licensed. Now you might well argue that's not fair, as you're not comparing like with like. But the customer will be looking at the total cost.
I'd still take a NetApp over a ZFS box with that spec any day, because at work we aren't really a UNIX shop and we don't have a large sysadmin team who could babysit a Solaris box. NetApp gives us end-to-end support covering all aspects of the hardware and software, which is fully integrated (I love AutoSupport!), and which more than pays for the price difference, and you still can't do clustered ZFS yet (although they do have RAID-Z2/Z3). But if we were bigger, and had a few Solaris storage-savvy guys to hand, then it would be a lot harder to justify.
My other point here is that WAFL and snapshots are under attack. ZFS's low level snapshot implementation doesn't have WAFL's limitations (255 per flexvol? for example) and as I said earlier, btrfs is in development with Oracle doing another equivalent. I still don't really understand what OnCommand is other than a rebranding of NA's (excellent) management toolset. I'd agree that the management tools are a key differentiator here but it won't take long for competitors to come up with equivalents.