There's a report on TechCrunch that he got an OTA Froyo update, but there's only a handful of other people confirming this. Most of the people on XDA haven't received it yet either, so it could be BS.
http://techcrunch.com/2010/05/22/and...ch+(TechCrunch)
http://forum.xda-developers.com/showthread.php?t=686326
Since I'm on a custom ROM, I can't get it OTA, so we're patiently waiting for someone to post an update.zip for us.