The amount of apps in the Windows Phone Marketplace
Microsoft's Windows Phone Marketplace has now reported to have passed 25,000 apps by one site tracking comings and goings within it. (source: WindowsPhoneAppslist, July 2011)
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I'm not a lawyer (yet) but my gut instinct is that, if Apple is not simply being greedy, this is an issue because it is a *significant* upgrade rather than a minor firmware update or a security patch. After all you would normally expect someone to pay for a 802.11n upgrade if it was unadvertised (and they therefore did not at the time of purchase). If they don't have to pay for significant unadvertised features then you could sell 100 laptops to someone as 'broken' for $1 each (minus the OS say) and then 'upgrade' them for free, leaving you and the buyer to split the profits.
An 802.11n upgrade is significant, especially, and this is probably the killer point in light of how many additional units of apple TV and airport extremes Apple will sell because of it.
So I don't think that the accounting excuse is total bs. I suspect it is partly due to that and partly due to Apple wanting to make money.