There are a lot of Samsung phones out there that run on Android 2.1. Apparently phone carriers would have to pay a fee to Samsung every time an Android was updated on a phone. The carriers do not want to pay the fees so Android does not end up getting updated. Carriers make upgrade deals with handset companies when agreeing to sell phones. If there’s a critical need for a software update, then there is no charge. Maintenance software updates have small charges. But feature updates like a new version of an operating system requires costly updates.