This article doesn't even refute the idea of OS level fragmentation. They arbitrarily bundled two versions. If you look at the original data, the most share held by any single version of Android is 40.8%: <http://developer.android.com/resources/dashboard/platform-ve...; And it's not even the newest version!
The less spin-laden headline would be: "What fragmentation? 36% of devices run Android 2.2."
The less spin-laden headline would be: "What fragmentation? 36% of devices run Android 2.2."