"The descriptor '4G' ... conveys to consumers in Australia that the iPad with WiFi + 4G will deliver a superior level of service in terms of data transfer speed (consistent with accepted industry and regulatory use of that term), and not that the iPad with WiFi + 4G is compatible with any particular network technology promoted by a particular mobile service provider in Australia," said Apple in response to the complaint.
Essentially, Apple is trying to argue that "4G" does not refer to any specific technology, but that it applies to the data transfer speeds that a device is capable of. Carriers in the U.S., such as T-Mobile and AT&T, have been advertising their own HSPA+ networks as "4G" for some time, even though they are not considered "true 4G" networks by many. In fact, Apple recently updated the AT&T version of iPhone 4S to display a "4G" indicator where it once said "3G," even though the technology inside the iPhone 4S did not change.
