The distinction, though, is that you get to make that choice as the consumer. You can carry the phone with no case, or you can put a very rugged case on it, or something in between.

> The distinction, though, is that you get to make that choice

From the narrow point of view of "this option or nothing", yes.

For the more general purpose view of "imagine a non-rugged version", such a phone would have a lot less of a size/weight penalty.