My experience is that for ease of set up a Lyric or a Zeb is the best bet, if you really feel you can set up a Factory 36 or 38 correctly then they probably just edge it, but in my opinion you would have to be a hell of a rider to really notice.
I have a Factory 36, Lyric Ultimate, and Zeb Ultimate on various bikes, and my favourite fork in isolation is the Lyric, but thats on a mid travel bike.
In my opinion if you are running 170 or 180mm of travel a Zeb or 38 is a much better choice. I am not the world best rider, but there is a noticeable difference in stiffness on my 180mm Lyric vs 180mm Zeb. At lesser travel the stiffness difference is not really noticeable.
One thing worth noting too is brake rotor size.
If you are running a 220/223m front rotor, i would definitely go for a Zeb. The fact that the Zeb is direct mount for a 200mm rotor, means that you are running a relatively small adapter with a 220mm rotor. When running a 220mm rotor on the Lyrics/36’s, which are 180mm mount, you are using a big adapter, and i found the force of the big rotor going though the adapter meant that the brakes where constantly going out of alignment under heavy braking. Never had this issue on the Zeb. Also in my opinion the benefits of the extra stiffness is most noticeable under heavy braking, especially with a bigger rotor.
I dont know if the 38 is also 200mm mount, but same would apply if it is.