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Android users are making it hard for developers

As many Android users go for cheap phones and tablets and prefer free apps, they are making it difficult for Android developers to make a living.
At least according to this article:
Another problem is the fragmented market; the majority of Android devices still uses an old version of the os (2 or even earlier), which can't always be updated. Only a few have Android 3 or 4. Which makes it hard for developers to make apps that suites them all and make a living too.