The problem is Sarbanes-Oxley requires compliance with certain accounting practices (to be set by regulators; these are not spelled out in the act). I'm not an

The problem is Sarbanes-Oxley requires compliance with certain accounting practices (to be set by regulators; these are not spelled out in the act). I'm not an accountant, but as I understand the problem arises in this situation: 2005: Company X sells product Y to person Z for $1000. Company's books show $1000 in revenue. 2006: Company X gives Z a free significant upgrade to product Y and records no revenue. The argument could be made that what really happened was that the company actually made two sales to Z; one in 2005 and one in 2006 and that the revenue of $1000 should properly be split across the two years. Not having such a rule apparently allows various accounting shenanigans in which totally unrelated things are treated as "free upgrades" to something else and revenue can be booked in whatever year you want. So there are two important things here for all this to be an issue: 1) The initial purchase must have cost money. If you get something for free and then get a free upgrade to it, there's no problem. 2) The magnitude of the upgrade must be such that one could be accused of slipping an unrelated product in as a "free upgrade". So for example security updates to safari would fail test #2 above. Major updates to iTunes may fail test #1, since iTunes is generally available for free to everyone (even if you don't buy a Mac or MacOS). It's possible that something makes Apple's accountants feel that XCode is part of the OS in a way that means that when you pay for the OS you're also paying for XCode. And that XCode 4 is enough of a change from XCode 3 that if it were free it would fall afoul of the accounting stuff above. Again, I'm not an accountant, so I could be getting all this totally wrong...