Well, consider the options.

Noob Saibot has a flash beam attack that makes him similar to Jade. And since he is one of the unlockable matches in UMK3, I guess Noob Saibot could beat him.

The only way he could though is to utilize that flash beam attack. This would negate any freeze that Sub-Zero would try to throw.

And besides, he is pretty hard to see when your playing. I can see him, but if I decide to play the UMK game for the DS, I can barely see him (one of my biggest advantages is playing in the dark with some lighting). This makes him hard to notice when he decides to either teleport or actually unleash a combo.