Depends on how you look at it. I think the albeit cringe inducing part where they said 'we are as disappointed as our fans' was a way of apologising, just without the part that involves smashing their dignity into little microscopic pieces with a sledgehammer.
Guess it depends on the person interpreting it.
Personally I have one friend in particular that's too proud to actually SAY she's sorry. She'll act like it, suddenly being a lot nicer or more considerate with future issues, but boy she's taught me that no, actions don't always speak louder than words. Annoys the snot outta me that she can be too proud to say she's sorry when she screws up.
Same thing here, really. I don't think they should expect PS3 customers to fill in the blanks and say "Bethesda meant to say sorry." No wtf make them say it. They're a friggin' company; pleasing their customers is their job. Not apologizing when the complaints seem so blatant and obvious....Iunno why it bugs me (since I'm not buying Dawnguard, nor am I a PS3 user) but it does.

Maybe it's because it just makes Bethesda seem kinda out of touch with the fans here, and that kinda scares me.