There really isn't a simple answer to your question. If you are trying to bulk up, then anytime you come up short on calories is a lost opportunity.
If your buddy's last meal of the day is in the evening and his next meal after breakfast is not until noon and he only has a couple hundred calories at breakfast then yes, there probably is room for improvement.
On the other hand, if he has a meal in the middle of the night and a healthy 'second breakfast' then maybe he is doing ok.
See where this is going? Trying to prioritize meal 'importance' is kind of futile because it is very situational.