I think you may be confused... there are TWO different rules. 1) NCAA Rule 9-1-3, Targeting and Making Forcable Contact with the crown of the Helment. 2) NCAA Rule 9-1-4 Targeting and Making Forcible contact to head or neck area of a defenseless player.
Rule 9-1-3 has nothing to do with a defenseless player.
I would say he was in violation of rule 9-1-3, but not 9-1-4; however, there are notes applied to 9-1-3 and 9-1-4 that state the the meaning of targeting as a player takes aim at an opponent for purposes of attacking with forcable contact that goes beyond making a legal tackle or block or playing the ball.
One could conclude that the crown of the helmet hit the facemask in the course of a normal tackle and even though it was "forcable" it was not intentional beyond the normal bounds of making the tackle. This is what I think the Replay ref based his call lack no-call on (IMO). Basically, using the same note applied that give a no-call to the hit on Hurts in the Ole Miss game. The only difference being the Hurts hit would fall under 9-1-4, not 9-1.3, but the note applies to both rules.