Apparently, and rather suddenly, ATT has caught onto this "loophole". When I called Business Key Customer Support, the CSR explained to me exactly what people were doing in order to become upgrade eligible. And as such, they were updating their systems accordingly which is why some people eligibility has now become ineligible. Mostly, it affects those who have sold their iPhone, decided to keep the iPhone package on their account and are now using a second rate phone until 3G is released. The CSR told me as long as your account's default phone is the v1 iPhone, then you'll be fine come tomorrow, if not, well, time will tell. I suggest bringing in an activated iPhone.