Boy Genius Report did some checking around and found Techcrunch's 30-40% Android return rate a bit too far-fetched.
After checking with their "sources", they find that returns are closer to single-digit percentages. And with some major screw-ups, even those are just in the teens.
If it was in the 30 to 40% return rates as TC suggests, the handset makers would be going out of business. I hope TC responds with a follow-up.