Apple's Flash in Plan

But Samsung's rivals could use help in expanding their capacity, and they'd likely be willing to give Apple a better deal in return for its cash.

"This is not necessarily something they have to do with Samsung," says Unsworth. "They don't have the leverage over Samsung that they do with some of [Samsung's] competitors."

Of course, not everyone is convinced that Apple is serious about investing in flash production. Even without an investment, the company was able to secure a huge chunk of Samsung's flash capacity at a discounted price, says analyst Jim Handy, who covers the flash memory market for research firm Semico.

And a production investment would essentially lock Apple in with one supplier. That could make it difficult for Apple to change course if the supplier had quality-control problems or if another supplier developed better technology.

"I'm still questioning whether this deal ever existed. I'm really skeptical of stuff like this," says Handy. "It would be a very big change in strategy by Apple for them to do this."

It would be, but Apple has done it before.