In some ways, Android has adopted the same position on the smartphone as Windows occupies on the desktop--it's become the default platform for hardware vendors to use who don't want to go to the expense of developing proprietary software.

That doesn't mean people are necessarily opting for Android as their preferred choice. Because Android is used by the majority of different smartphone manufacturers, the growth in its userbase is likely just an indication that the smartphone marketplace is growing.

The MobiLens data matches , which puts Android's share at 35 percent, although puts Android even higher at around 50 percent of the marketplace.

Microsoft and Palm also saw modest declines in market share since January, according to the MobiLens survey. Microsoft dropped half a percentage point, while Palm dropped 0.4 percentage points. Microsoft will be dismayed as customers vote with their wallets when it comes to the launched late last year.

On the flip side: After a slight slip in January, Apple's market share continues a slow but steady rate of growth. The launch of the might be helping, along with the fact are becoming more competitive in preparation for the arrival of . It'll be interesting to see if the recently released white iPhone significantly boosts Apple's numbers.