Remember that Netflix's CEO, Reed Hastings, is on the board of MSFT. This is the same reason used why Netflix for linux isn't available (it uses Silverlight and the linux version doesn't effectively support DRM). The cynic in me would love to think that this jab at Android isn't just a strategic move to help Windows Phone in it's fragile fledgling state. However, my understanding is that Netflix's hands are tied on the issue of DRM, if they don't support it, the content owners won't let them stream, much like iTunes was for music in the early days.