I've been thinking more about this discussion. The Peterson has a claimed accuracy of 1/10 cent. There is, of course, a difference between precision and accuracy. The former refers to the tolerance and/or repeatability of a measure; the latter refers to how close the measure is to the true value. I have no difficulty accepting that the stroboscopic display of the Peterson allows for a precision of 1/10 cent. When the frequency at the input of the device deviates from what the device "thinks" is the correct value, you see the display "move" one way or the other. Using the perception of motion in this way is, and has been for decades, a very clever idea. What the device "thinks" is correct goes to accuracy. Now, consider this. For the Peterson to be accurate to within 1/10 cent means that at 440 Hz it is calibrated to within about 25/1000 of 1 Hz!
Take a look at the Peterson's text for their Stroborack tuner:
Precision Accuracy
An important advantage of Virtual Strobe Technology™ is that no “in tune/out of tune” decision is ever made electronically-a process inherently subject to inaccuracy. Your eye simply interprets the motion of the pattern as an indication of tuning error relative to the target pitch. Only this method provides the high level of resolution in a Peterson strobe tuner that allows unprecedented accuracy in tuning to "standard" pitches and permits one to utilize the subtler shades of altered temperaments and Sweeteners™ found as presets in our tuners. It is this superior precision that also allows user-programmed tunings with up to 1/10th cent resolution settings to be achieved.
"Precision Accuracy"? Is it precision or accuracy? The context seems to make clear that they're talking about resolution (precision) and not accuracy. That is, the user can discern a 1/10 cent change. In the specs that same resolution is claimed as the accuracy. Confused? You should be.
For now, I accept that the Peterson display allows for a deviation of 1/10 cent to be discerned. That's a hallmark of their stroboscopic display. Do I believe that the $70 Strobolclip is accurate to within 25/1000 of 1 Hz at 440 Hz. No, I don't. Certainly not at all temperatures under which it might be used.
I'm guessing that the actual accuracy of the Peterson Stroboclip is as good or better than the less expensive tuners on the market. That, coupled with its superior precision (resolution) makes it a fine deal for those who desire to be able to discern such small deviations.