Just called ATT and they confirmed what I thought. If the account is not past due, I can buy a new iPhone for the subsidized price + $36 upgrade fee.We've gone over this before. "Early iPhone upgrade" is $250 on top of the $199/299/399 subsidized price.
That should be clear from the text. In the first one they mention the $250 + $36. In the second it just says $36.