Not misleading at all. "Market share" means exactly that -- the share of the market for smartphones.
Installed base is a different concept from market share.
Statcounter is a proxy for installed base rather than market share. It therefore presents an outdated picture of a fast-moving market. Blackberry above Windows Phone? iOS with 3/4 the share of Android?
Statcounter shouldn't ever be seen as representing marketshare or installed base, rather it represents usage share. If you buy a device but put in a drawer, it counts as market share but since it isn't being used day by day, it wouldn't count as usage share.
I wonder if the reason Nokia hasn't been crowing about the marketshare numbers in Europe is that it is a Pyrrhic victory won with massive discounts. If they are displacing their own feature phones (but without the profit margin), it would create the impression of an installed base, when people are primarily using it for telephony and texting.
When releasing a disguised press release, you can be a little loose with your math.
For example, say your overall market share is roughly 3.1% of the entire market. You just had a banner month and your sales were roughly 7.7% of total sales for the segment for that month. You can honestly say that your market share is "nearing" 10%. You say this knowing that many people will just read the headline or skim through the body. Now, many have a mental picture of your company actually having 10% market share.
Installed base is a different concept from market share.
Statcounter is a proxy for installed base rather than market share. It therefore presents an outdated picture of a fast-moving market. Blackberry above Windows Phone? iOS with 3/4 the share of Android?