That's not a bad ratio though, which is what I'm hoping to establish, of good:bad. While not technically translatable, lemon that is, to a phone; in my opinion if you're having to get a replacement after getting your initial new phone - it pretty much means it's suffering from more than just normal Android problems.
But 36 new and okay versus 3 bad isn't too horrible. It's a shame for those who did suffer a bad device, but I'm hoping this also alleviates some concerns that all of them are having issues. That whole "you only hear the bad stories" paradigm.