The vast majority of Android phones released in 2010 do not have Android OS 2.3 (Froyo) upgrades available for them. Microsoft has been criticized for the long delay in getting their relatively minor NoDo update to Windows Phone 7 devices. Tech-aware consumers have been impatient and annoyed by these situations. The Electronic Frontier Foundation (EFF) says it is much more than that:

Mobile Carrier Delays Harm Internet Security

The EFF places the blame squarely on the mobile phone carriers. But, will the carriers respond? I think it is unlikely as long as the delays and potential security risks do not impact their bottom line. The problem is that if a big mobile security issue arises, it could affect millions of users in the U.S. alone.