During today's Apple event, Steve Jobs bragged about how many iOS devices are upgraded each day and remarked that he thinks "some of [Apple's] friends are counting upgrades in their numbers." Google caught this thinly-veiled accusation and retorted:

The Android activation numbers do not include upgrades and are, in fact, only a portion of the Android devices in the market since we only include devices that have Google services.

Ouch! [Fortune via 9to5]