Good call Google aka the Android team. In a recent blog post on Google's own Android Developers blog, Tim Bray, informed Android developers (and end-users) that, in order to provide the most intuitive and consistent user experience in apps, developers should migrate their app designs away from using the Menu button but using the action bar instead. For your background, before Android 3.0/Honeycomb, all Android-powered devices included a dedicated Menu button and developers were able to use the Menu button to display whatever options were relevant to the user, often using the activity's built-in options menu.
The old and now wrong way to place the menu button (Twitter app)
However, Honeycomb, followed by Android 4.0/Ice Cream Sandwich, removed the reliance on physical buttons, and introduced the ActionBar class as the standard solution to make actions from the user options immediately visible and quick to invoke. This isn't, according to Google, a new concept - the action bar pattern has been around on Android even before Honeycomb - but as Ice Cream Sandwich rolls out to more devices, Bray highlighted that it's important that developers begin to migrate your designs to the action bar in order to promote a consistent Android user experience.
The new and now right way to place the menu button (Android Market app)
So far so good! Unfortunately Google's very own Google Docs application is even worse since it shows the Menur button in the lower right corner (old) as well as in the upper right corner (new) but doesn't matter which of the two menu buttons is tapped, it always opens on the top.
The totally wrong way (before and after) to place several menu buttons (Google Docs app)
Well, that's what I would call an inconstant user experience and before Google asks its Android developers out there, it might want to do its very own homework first, right?
Cheers ~ Arne