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Survey is comparing current 3GS, 4 and 4S users. People who use their phones most are most likely to have upgraded to 4S and people who use it infrequently are more likely to still be on the old (or cheap) handset, i.e. the 3GS. I wouldn't be surprised if the average data usage of iPhone 4 users has actually come down since the 4S launch due to the heavy users upgrading.
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