He may be talking about the RT models, which lack the digitizer of the Pro but still have the ability to run RT versions of apps like Sketchbook Pro
Microsoft's own Fresh Paint app is another one that could benefit from this. One thing to note is that all of the Bluetooth styli released so far on iOS are exclusive to Apple's platform. An exception is Hex JaJa, which is cross-platform between iOS and Android, but it's not a Bluetooth stylus either - it utilises high-pitch sounds delivered via microphone.