im sure a VZW rep offered it to him for free for having trouble for his eris. but he did extend his contract though. i didnt have to pay, extend my contract, or use someone elses upgrade. i guess for that you have to catch a really nice rep.
EDIT: OK ill tell you this. When i had problems with my Eris, i had to work much harder. i had to calll and call and call and call constantly til i got someone willing and generous enough to switch me to a different device. also everytime i called i explained all my problems and whined about how im constantly putting up with problems with this these Erises. eventually i got a guy who cared enough to switch me to a MotoDroid.
my 2nd time going through this type of thing with the droid wasnt as much of a hassle. on my very first call on that day the guy immediately skipped trouble shooting and went straight to pulling some strings to get me to a different device (the droid2)
so i would say keep calling until you get your way. eventually youll get someone caring because those generous reps who care are still in existence. you just have to hunt them down if they dont