A smart phone that can't update to
the latest version of software is considered outgraded when the rest of
the market upgrades to the latest version. Likewise when a manufacter releases the newest line of a product, say TV's, and only their newest line is allowed to have the latest features, or run the newest Apps; then
last year's model has been outgraded.
His phone has been outgraded ever since Android 3.4 was released.