You could post the update on a website. It would require communicating with those old users that it was available. You wouldn't be able to use the market to prompt them to update unless you published it, which of course would allow new users access as well. In addition, in order for a user to update the app, they would have to check the box for non- market apps. This will be a problem for any user on the AT&T network as they won't be able to do that. This is probably a moot point though as AT&T hasn't had Android devices very long.
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