Thats what it sounds like. Some people are elgible for a fully subsidized upgrade after a year becasue of how much they spend every month and pay on time.
Check with your carrier to know for sure.
The following is for AT&T:
Not all Cingular/AT&T customers may qualify for a cell phone upgrade. At this time, AT&T Mobility allows these customers to upgrade with no upgrade fee when they commit to a new 2-year contract:
* AT&T customers who have had 24 months of cell phone service since activation of their cell phone or since their last phone upgrade.
Certain AT&T customers may be eligible for a cell phone upgrade even if they have been in their current plan for less than two years (24 months), if they commit to a new 2-year contract and meet these eligibility requirements:
* Customer has had a standard calling plan plus data services costing at least $68.99 a month but no more than $98.99 a month, and who has been in contract (and not had a phone upgrade) for 21 months or more,
or
* Customer has had a standard calling plan plus data services costing $99 a month or more, and who has been in contract (and not upgraded) in the last 12 months.
A customer with a calling plan and data services of less than $69 who is 21 to 23 months into contract may upgrade for a fee and a commitment of an additional two-year service contract extension. No upgrade fee is assessed for any customers who are on a month-to-month agreement.
Note that AT&T upgrade eligibility may be further limited based on customers usage history, payment record, previous phone replacement, etc. Upgrade eligibility is solely determined by AT&T Mobility at its discretion.
http://www.wirefly.com/upgrades/eligibility/att/
