Apparently this didn't even happen until 2018, and only then as a limited-time promo! https://www.windowscentral.com/microsoft-slashes-windows-pho...
To be sure, as noted in this 12-year-old Reddit thread on the program https://www.reddit.com/r/windowsphone/comments/1e6b24/if_mic... - part of the reason for a fee-to-publish is to prevent malware and other bad actors. But it's not the only way to do so.
First-movers can get revenue from supply-quality guardrails. Second-movers need to be hyper-conscious that suppliers have every reason not to invest time in their platform, and they have to innovate on how to set up quality guardrails in other way.
And it continues to this day, when one looks at the QC/Windows laptop pricing, or various other trailing technology stacks that think they can compete in apples playground.
It reminds me of the failure of Windows Home Server. It was removed from MSDN because the product manager said developers needed to buy a copy of it if they wanted to develop extensions and products for Home Server. Very few bothered. However many dozen licenses the policy lead to being purchased was dwarfed by the failure of the product to gain market share. Obviously that wasn't only due to alienating developers but it certainly was part of it.