[nicholassmith]

Probably not, at least when Apple says "Hey, we sold Xmillion copies of Mountain Lion" you know that they're pretty much talking about how many people have installed it. Same with Android and iOS when they talk about how many activations they've seen, as a developer you instantly get the number of users you're going to potentially have as an audience. Juicing the numbers is not going to woo developers who can see right through it.