Years ago (when Palm was the only game in town), developers were offered significant discounts on Palm devices intended for testing. OK, not the kind of discounts Nokia gives – but nevertheless quite a bit. However, word spread – and the service was discontinued.
Developer phone purchase has now been resumed:

The devices are discounted by 20 percent and are sold in US dollars, which leads to a rebate of about 33% for Europeans. However, no data plan or anything is included – and as European carriers usually don’t give you lower monthly rates for bringing a cell phone of your own, well, you get the idea…
Further information on this – admittedly rather useless – offer can be found below:
http://www.palm.com/us/products/phones/developer-phones.html
P.S. To the Palm folks reading this: what about carrier-unlocked webOS phones? They would make you a nice bit of cash…
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