For phones, sure, but certainly not for tablets. By the time that consumers can actually buy RIM's PlayBook tablet, how many developers will still be writing tablet apps for Android 2.3? All Android tablets that have any chance of taking market share from the iPad run Android 3 (Motorola's Xoom, Samsung's Galaxy Tab 10.1, etc).
And yet Apple also trumpeted the numbers of apps available for the iPad on launch, despite the vast majority of these being iPhone or iPod Touch apps not optimised for the tablet.
That was a year ago, when they had no competition. Now the iPad has 65,000 apps optimized for its form factor. You don't get to compete with last year and still win.
Uh. 3.0 was created specifically to address tablet concerns, was it not? 2.3 is still the new hotness for phones.