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Stolen devices are an edge case because it removes the incentive to steal the devices. Back when mobile phones first started becoming popular they were an equally popular smash-and-grab item. Now? Not so much.

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Devices are (and have been) stolen and sold to strip them for parts. The value may be lower, but it’s nowhere close to zero.

But most phones don't have physical reset buttons, so all of them have this kind of protection without the shenanigans of account de-association.

Are there any extant android devices that can't be factory reset from the bootloader menu?

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