The relative positions of the center of the diaphragm and the mouthpiece account for much of the difference. When looking up, or worse, straight up, a seconds tage of conventional design will have the the diaphragm at the highest point in the reg and if the center of the diaphragm is above the mouthpiece, additional inhaltion effort (cracking effort) will be required to overcome the reduced water pressure acting on the diaphragm.
Conversely, if you are looking downward with a conventional second stage design, the center of the diaphragm will be lower than the mouthpiece and more water pressure will be assisting the diver in opening the valve so inhaltion effort will be reduced. In the same situation the diaphragm is also substnatially lower than the upper edge of the exhaust valve so in some cases, if the cracking effort of the valve is too light, air in the second stage leaking out the elevated exhaust valve will cause the pressure in the second stage to decrease enough to open the poppet and start a slight freeflow.
So beathing resistance will change with the angle of the second stage. With a second stage with a diver adjustable cracking effort, you can change the cracking effort to accomodate the change in position. With a non-adjustable second stage, the cracking effort will need to be adjusted as a compromise so that it is high enough to prevent a freeflow when face down and yet as light as possible to minimize cracking effort in normal swimming and face up positions.
This is where regs like the Scubapro D300, D350, D400 and the Dacor Quantum shine as their exhaust valves are co-axially mounted in the center of the diaphragm so the maximum height difference is never more than about .5 inches. The D300/350/400 has a further advantage in that the angle of the diaphragm changes the worst case postion to positions not normally experienced by divers. So the lack of a diver adjustable cracking effort is not missed as the reg breathes the same regardless of position.