Shipments with vendors like Samsung, HTC etc involve pushing product into the channel (distributors, wholesalers, retailers) in anticipation of the Christmas sales. Vendors can often push (or "ship") a large amount of inventory into the channel on very liberal credit and return policies.
Also, they're saying smart phones. Which does not mean "high end". Basic phones do email and internet browsing and can be considered "smart".
Apple on the other hand reports product sold v/s shipped.
Not saying that its been done by Samsung and the like... but it is common practice in a channel driven model.