Google has since updated its documentation to prohibit the use of AdSense in a mobile application:
"Using AdSense for mobile in a mobile application is in violation of AdSense rules. A mobile application is any downloadable application, even if WebView is used to display an ad. Any AdSense for mobile ad units found in mobile applications will be disabled. If you are looking for an advertising solution for of your mobile app, sign up for AdMob, Googles, the leading mobile ad product. "
The solution is to use the dedicated PhoneGap plugin .
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