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Market Share and OS Versions

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After reading an article about how the Nexus One isn’t getting upgraded to the newest version of Android, I got to thinking. Most people would agree that marketshare is a important indicator of a platform’s success and developer interest in that platform, but from a developer point of view, I want to know the market share of devices that can run the newest version of the OS. If a manufacturer is saying that their device is too old to be able to be upgraded to the newest version of an OS, should it really be considered a X device anymore? All of these Android phones that are stuck at 2.3 or 2.2 or 1.6 or whatever, should those really count as market share? At what point do those go away? Likewise with Apple devices, if it can’t run the latest and greatest iOS version, I don’t think it should count in market share. Okay, maybe still lump everything into ‘Unit Market Share’ but we should have a new measurement, maybe called ‘Active Unit Market Share’. Active Unit Market Share only includes devices that are capable AND can update (read: the update is released) to the most recent version of the OS.