In addition to cell-phone users being left out of most polls, so are the folks who have switched to VOIP.
http://www.electoral-vote.com/A reader pointed out another block of voters who are missed in telephone polls: people using Internet telephone companies such as Vonage. Early adopters of new technologies like VoIP (Voice over IP) are typically highly skilled urban professionals with college degrees working in modern industries. This is prime Kerry territory. Their numbers are still small, but here is another example of voters who are predominantly pro Kerry being undersampled by the telephone polls. As a compensation, they are likely to be oversampled in Zogby's interactive polls. In any event, this raises yet another methodological issue.
VoIP raises another issue: area code. Some of the VoIP carriers allow the customer to pick the area code. One reader from Chicago said his Vonage phone number has a Georgia area code so his mother in Georgia can call him without incurring long-distance charges. This effect means if a pollster did call him, his vote would be counted in the wrong state.