I'm pretty sure fenix, like most of the other manufacturers use bulb lumens. The only type of light that can put out 200+ lumens pass the lens is something with a P7 emitter.
Check out the comparison pics.
The fenix P3D is rated for 215 lumens. The fenix TK10 is rated for 225 lumens. The surefire is rated for 120 lumens. I think the results speak for themselves.