This was true with previous versions of Windows. Microsoft has changed how licenses to OEMs are distributed. Instead of ordering in bulk lots, license is purchased by an OEM on a per install basis. This change in how the OEM license works would mean that the figures should be lower, not higher. But another important thing to note is that Downgrade Rights sales would definately count, even if the end result is that an end user received a PC with Windows 7 installed on it. It is possible that they are counting at least those 2 million Surface tablets...