I got an iPhone from a relative, the relative had forgotten the passcode and the Apple ID password.
I did a factory reset of it via iTunes and of course when it started up and I started with the setup it said it was locked to *@*.com.
I contacted Apple support and they said I needed proof of purchase for them to unlock it.
I did not have any proof of purchase and neither did my relative.
But I refused to let that stop me. So I made a proof of purchase, printed it and went to an Apple store.
I told the Apple Genius about the iPhone and that it was locked but factory reset and presented the "proof of purchase".
The Apple Genius went to get a manager or something and the manager checked the "proof of purchase" and then connected the iPhone to the store Wi-Fi and did some stuff on their iPad and rebooted the iPhone. The iPhone did a reset and then it was unlocked and ready to be setup without any hurdles.
So I am guessing some thieves have figured this out.