A Google spokesperson told Wired.com that the idea is make sure only apps compatible with the OS are shown to the user.

But that also makes it difficult for apps to truly go viral. If you hear your friends talking about Gesture Search, your next step is probably going to be searching for it in the Android Market on your phone. Unless you know what version of Android you’re running, you’ll have no idea why the app you want doesn’t show up.

“From the customer-support perspective, this happens almost every single day,” says Froogloid’s Fagan. “I receive an email from an older Android OS user saying, ‘I am having trouble downloading your app and I don’t see it anywhere in the marketplace.'”

Froogloid’s popular Key Ring app only supports Android versions 1.5 and higher.

Sometimes, putting an older version of the Android OS on the phone is a shrewd marketing decision, says Sutton. Older versions of the Android operating system allow telecom carriers to charge for features that would be otherwise available for free, like navigation.

Though Motorola and HTC say they will upgrade some of the phones to the latest version of Android, Sutton says consumers shouldn’t assume it will be the case with every phone.

Upgrading the OS consumes resources and many companies don’t want to take that on, he says.

“The larger the company is and larger the installed base of phones, the more time it takes to get out those updates,” says Sutton. “And nine of out 10 times, when the company has to make a decision on whether they are going to update the firmware or not, they will say they won’t do it because people already have their product.”