I've heard that said many times in terms of sales. Do you really think that it applies to review scores as well?

I mean you could suggest that some niche android-powered device might so neatly fit some weird need that it gets full marks from the 3 people who buy it, which would be higher than the average of all iPhone reviews. But the example in the article is the multi-million selling Galaxy S.

(Note also it's UK focused, so AT&T versus Verizon doesn't apply)