Can a used iPhone "become iCloud locked"?

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probably silly question looking @ used iphones on ebay , selling 5s has activation lock icloud on it. in listing claim lock appeared month after bought phone on ebay themselves.

if can happen seems worrying looking buy used iphone, question can happen or seller talking bs because phone stolen?

seems logical me if phone wiped clean before buy it, set own icloud account, previous owner cannot lock it. if buy used iphone need make sure previous owner's icloud account not still set up. right?

thanks!
 

it can't random become locked out of nowhere. can become locked if wiped remotely or through dfu restore , actual owner of phone doesn't put in icloud password activate again. can't think of scenario owner forget both password , email address. 90% of time icloud locked equivalent of stolen.
 


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