A Windows Mobile 2003 Second Edition update for the Toshiba e800/e805 has been posted on Toshiba's European site.
Both the Bluetooth and built-in Wi-Fi versions of the e800 can be upgraded using the files posted.
The operating system update process is somewhat complex so read the directions carefully. We know of one user who tried an update and had to get a replacement unit when the update failed. A Windows Mobile SE update for the e405 is expected from Toshiba in June.