That's unlikely, mobile device lifecycles are way shorter than those of desktop computers. Even native game developers often don't target mobile devices that are outdated.
Android 2.3.3+ = 50.79 % Android 2.2 = 23.87 % Android 2.1 = 7.22 % Android 4.0.3 = 1.42 %
As a developer, am I really going to only target my html5 or native app for 4.0.3?
p.s. Sorry for the delayed reply. :)