Ahhhh! That Trikky is a man of rare wisdom and insight.
Many folks blame the seals for leaking in this area. And often they are correct. There are good seals (cork and rubber mix) and not so good seals. But the whole situation down there in rocker cover heat exchanger land can involve other factors. The bail for the rocker cover can give up the ghost and just not hold the rocker cover in place tightly enough. Then too, the casting hole in the head that hold the bail can wallow out and affect its tension on the rocker cover. And that's not all....... the heads can have nicks and grooves in the mating surface where the seal makes contact. The rocker covers themselves can warp. And as Trikky notes, that is especially true of non-OEM covers. Those racy finned aluminum covers are just notorious this side of pond for spilling oil. Real BP specials!