At least in theory, when buying a refurbished phone, is there a chance the phone has been modified, in the same vein as phishing, to look like a stock installation, down to the "factory reset" and maybe even appear rooted?
I.e., if a company bought 300 refurbished phones off eBay...
I suppose running Wireshark to see what's coming in or out might be a good start but I am hoping someone will say it's extremely unlikely (given that nothing's impossible).