Check out this thread 
http://groups.google.com/group/android-developers/browse_frm/thread/9ccf30f7c3f20a3

basically you need to put that right under <manifest>, at least that's
what people on that thread are saying and it worked for me.

~clark

On Apr 24, 7:17 pm, "[email protected]" <[email protected]> wrote:
> Hi - I just tried tonight (4/24) to upload an upgraded to my app, and
> saw something new.  It won't let me do it, saying that the market
> requires a minsdkversion spec in the manifest.
>
> So I sez to meself:  "OK, I'll just put one in there."  Here is what I
> put, but it didn't solve the problem - no change in results when I try
> to upload the upgrade:
>
>         <uses-sdk minSdkVersion="1" />
>
> I put that right where my "uses-permission" lines are.  I am using 1.0
> SDK.
>
> Anyone else having problems with this, or perhaps see a problem with
> my spec in the manifest.
>
> Thanks much!!
>
> - Wes
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