Gee, that's strange. How could I possibly have used my iPhones in the car (handsfree or windshield suction mount)? On during a meeting (speakerphone)? Or at my desk while typing with both hands (headset)?
Well, even though you never acknowledge when your arguments have been demolished, in this instance you are correct so I will rephrase...
"Phones are most commonly held when used"
the point I was making stands though.