There were already signs that Microsoft’s (MSFT) Windows Phone app market might be a bit more lively than expected before Apple’s (AAPL) big patent win over Samsung (005930). Now, the threat of U.S. handset sales injunctions and possible new litigation against HTC (2498), Sony (SNE), LG (066570) and other Android vendors could give Windows Phone some extra oomph.

In a recent Vision Mobile study, 37% of the app developers polled were currently using Microsoft’s mobile platform. This was well below Android at 76% and iOS at 66%, but it already tops BlackBerry OS at 34%.

Implausibly, 57% of developers said they were planning to adopt Windows Phone in the future.

Windows Phone crossed the 100,000 app threshold in June 2012. The number lags far behind the iOS App Store, which now tops 700,000. But Windows Phone hit the 100,000 mark in 20 months – four months faster than Android and four months slower than iOS. That isn’t half bad.

Anecdotally, several app developers have recently indicated they are interested in the Windows Phone platform. “Doodle Jump” developer Igor Pusenjak mentioned to us during an interview last week that he is intrigued.

Will the early fascination actually translate to tangible developer support? That depends largely on Windows Phone sales and how many buyers actually begin paying for apps. But the recent litigation drama may have an impact if Apple manages to get injunctions slapped on Samsung smartphones.

Right now, Apple is demanding a ban on no fewer than eight different Samsung Galaxy variants. If those injunctions are granted — and if Apple starts gunning for other Android vendors — Windows Phone handset sales prospects could improve.

One factor here is the long-simmering developer frustration regarding Android. Many app developers we have interviewed over the past three months have been very vocal about their negative views on the Android app market, though none want to air their grievances in public.

Android is the No.1 smartphone hardware platform globally and in North America, but few app developers volunteer to get quoted about how they really feel about it as an app platform. None seem very happy. Trying to charge for Android apps is widely viewed as futile, and many regard the fragmentation and support challenges as daunting.

Windows Phone still faces a veritable mountain to climb as a mobile operating system, but the platform’s odds are a little bit better following a series of BlackBerry 10 delays and the new Android patent drama.