Open for publishing, not buying.

Easy, one just had to have a business and apply to it.

They even had contests for apps. I did apply to one at Vodafone when the Sharp GX20 was released, to show off the device capabilities.

https://www.gamedev.net/forums/topic/166989-vodafone-javatm-...

> Vodafone is pleased to annouce the Vodafone Java(tm) Games Challenge 2003 - a competition for J2ME games developers. The top three winners will receive: - A Sharp-GX20 - The new Vodafone live! handset with QVGA screen resolution - A commercial contract with Vodafone to deploy the winning games onto Vodafone live! in several countries Vodafone live! currently attracts 1.5 million customers across 13 countries. Register at www.via.vodafone.com and submit your games by August, 1st !

And while they had lots of trash, the gatekeeping kept it lower than current store offerings full of copy-cats.