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How to avoid stolen phones on eBay?

I've only had experience buying unlocked GSM phones from large eBay stores. I was thinking of getting a Garminfone for $300ish on T-mobile but most of the sellers don't have their own eBay stores and are just small time sellers with less than 100 feedback and such. How do I make sure I'm not getting a stolen phone? I hear a lot about ESN numbers for CDMA carriers, but what about GSM phones? Do they have theft protection that bricks the phone as well?
 
In the United States there is no blacklisting for GSM phones, so reporting as stolen wouldn't have any effect on it. Insert your SIM and go. There are still concerns when buying used from non reputable sellers such as mistreated/abused handsets or ones with defects that aren't initially apparent.
 
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