Review: Samsung T809

Bose may talk about "room-filling" or "enveloping" sound from their stereo speakers, but that's not "surround". If Bose sells speakers as "surround" then you can bet there are more than two speaker drivers involved.

Even the single-enclosure "surround bar" speakers have more than two drivers in there. A TV could have "surround sound" with four speakers aimed in different directions. It would sound crappy compared to separate speakers, but it wouldn't be false advertising.

A phone with two speakers and advertised as "surround" would be false advertising.

But come to think of it, I don't see that many phones advertised that way. What I do see are phones with "3D stereo" sound... which is a pure marketing invention that means almost nothing... or it means a sound processing effect that - technically - is distorting the sound by equalizing the levels differently or adding a slight echo, etc. so it sounds more "interesting".