"Microsoft can go in to all these accounts and say, 'Let us remind you again of the cost of Android,'" Dediu said. "What Microsoft has always had trouble with is getting these vendors to switch." Samsung sells dozens of Android phone models, according to its website, compared with three for Microsoft. Microsoft could also boast it offers legal protection that Google, by giving away Android for free to vendors, hasn't provided, Dediu said. "With Windows phones, you're protected against IP lawsuits because, if anybody sues, they are going to talk with Microsoft," he said. "Microsoft can do that because they actually do have their IP pretty well sorted out."