Fahrenheit Fact no. 22: Gore didn't win "every recount scenario"

In Fahrenheit 9/11, Moore asserts that Gore won the election, even after vote recounts. From the film:
NARRATOR: And hope that the other side will just sit by and wait for the phone to ring. And even if numerous independent investigations prove that Gore got the most votes... JEFFREY TOBIN: If there was a statewide recount, under every scenario, Gore won the election.
Now, it is true that many post-election investigations claimed Gore had won. But under every scenario? Turns out, no. From the LA Times:
WASHINGTON — If the U.S. Supreme Court had allowed Florida's courts to finish their abortive recount of last year's deadlocked presidential election, President Bush probably still would have won by several hundred votes, a comprehensive study of the uncounted ballots has found. But if the recount had been held under new vote-counting rules that Florida and other states now are adopting--rules aimed at recording the intentions of as many voters as possible--Democratic candidate Al Gore probably would have won, although by an even thinner margin, the study found. The study provides evidence that more Florida voters attempted to vote for Gore than for Bush--but so many Gore voters marked their ballots improperly that Bush received more valid votes. As a result, under rules devised by the Florida Supreme Court and accepted by the Gore campaign at the time, Bush probably would have won a recount, the study found. Since the study was launched, the nation's debate over the Florida recount has cooled and Bush, whose legitimacy as president already was accepted by a large majority in January, has won massive public approval for his leadership of the war against terrorism. The study, a painstaking inspection of 175,010 Florida ballots that were not included in the state's certified tally, found as many as 23,799 additional, potentially valid votes for Gore or Bush. The significance of these ballots depends on what standards are used to weigh their validity. Under some recount rules, Bush wins. Under others, Gore wins.
So yes, Gore did win some recount scenarios. But so did Bush- clearly at odds with the "every scenario" Bush loss claim that "Fahrenheit 9/11" makes. -a_sdf