While Google continues to roll out Android updates—they're all the way up to 2.2—the Behold II has been stuck on 1.5 since the phone's release. And according to Samsung technical support, it'll stay stuck there forever:
Thank you for your inquiry. The SGH-T939 will never qualify for the Android 2X update.
Your continued interest in Samsung products is appreciated.
More daunting than any potential legal action—which at this point is limited to a sad online petition asking for a refund, update, or replacement—is the persistent problem of Android fragmentation that the Behold II's woes bring into sharp relief.
Google's Android chief Andy Rubin spoke with Matt about that exact problem last week, although unfortunately there don't seem to be any ready answers on the horizon. Other, maybe, than not buying such a hideous phone to begin with.
UPDATE: Samsung sent us the following statement, confirming that 2.0 will never happen for the Behold II:
Samsung Mobile and T-Mobile USA are planning to update the Behold II to Android 1.6 which provides access to Google Maps Navigation, Google Voice Search capability and quick search box for Android. The update will also supply additional benefits including Swype, an improved Media Player, updated core Android applications and improved Bluetooth capabilities. However, the Behold II is not upgradeable beyond Android 1.6.