On 7/9/2012 2:11 AM, Tom Metro wrote:

I'm not sure if an active account is necessary in order to receive OS
updates, which unfortunately are brokered through the carrier. That's
one place you might be hampered, or it may just pull them from an
unauthenticated site. (If you are adventurous, load your own ROM, and
this will be irrelevant.)

Without a carrier plan you'll have to load your own ROM. Or you can get a Nexus phone where the updates come directly from Google.
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