Exactly. It is one of those things that Apple conveniently ignores when talking about fragmentation.Fragmentation is already in play. There was a new version of iOS 12 released the other day for phones that aren't eligible to be updated to 13.
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Apple Releases iOS 12.4.2 Update for Older iPhones and iPads
Though iOS 13 has been available for a week now, Apple today released an iOS 12.4.2 update designed for those who are still running versions of iOS...www.macrumors.com