Yeah, but even if they do, I don't imagine the free option lasting long -- after all, part of the reason Apple charges for being published on the App Store is ostensibly so they can support what is by all accounts a very robust testing/certification infrastructure. It's easy, then, to cast the non-App Store developers as freeloaders. The obvious end game is that either they're pushed toward the App Store (with carrots and sticks as mentioned above) or they're asked to foot the bill for testing of their apps.