Well, they don’t use Skyhook anymore in all new devices. Since iOS 3.2 in April 2010, Apple has been using its own database of cell towers and Wi-Fi hotspots. They’re building it automatically with their iOS devices.

“For devices running the iPhone OS versions 1.1.3 to 3.1, Apple relied on (and still relies on) databases maintained by Google and Skyhook Wireless (“Skyhook”) to provide location-based services. Beginning with the iPhone OS version 3.2 released in April 2010, Apple relies on its own databases to provide location-based services and for diagnostic purposes.”

“To provide location-based services, Apple must be able to determine quickly and precisely where a device is located. To do this, Apple maintains a secure database containing information regarding known locations of cell towers and Wi-Fi access points.”

“Information about nearby cell towers and Wi-Fi access points is collected and sent to Apple with the GPS coordinates of the device, if available: (1) when a customer requests current location information and (2) automatically, in some cases, to update and maintain databases with known location information.”

“…the device intermittently and anonymously collects Cell Tower and Wi-Fi Access Point Information from the cell towers and Wi-Fi access points that it can “see,” along with the device’s GPS coordinates, if available. This information is batched and then encrypted and transmitted to Apple over a Wi-Fi Internet connection every twelve house (or later if the device does not have Wi-Fi Internet access at that time).

from the Apple response to Markey and Barton