While she does primarily use it for music, she spends just as much time playing games and surfing the web. She can add games without connecting it to a computer, but it still requires a computer to get it that far.
It's just surprising that a device with so many capabilities (other than playing music) cannot do anything without that initial connection. You can't even just play around with the home screen icons!
Transferring an average music collection, say 10 gig, over USB2 is a much better way to do things than using WiFi. In addition, of course, although it seems you're mostly interested in being difficult and dishing out random pettiness, using WiFi would also involve making a connection to (gasp) your computer, where your music was likely residing before you purchased the mobile device in question.
So yes, Zero, I have "heard of" the Internet. I've also heard of plugging a cable in when it's much faster to do things that way, and when you have to plug the device in to charge it anyway, usually at least once daily.
If you're looking for someone being difficult and dishing out random pettiness you might want to re-read your own contribution to this thread.
As for the actual point, you still seem to think, despite the other answer, that an iPod Touch is only used for large, purchased music collections. That's not really true any longer with music available via Youtube, Spotify etc. and a variety of other diversions available (web, gaming, email, netflix, iPlayer) basically none of which require a(nother) computer to be involved.
It's just surprising that a device with so many capabilities (other than playing music) cannot do anything without that initial connection. You can't even just play around with the home screen icons!