[manarth]

Hypothetically, it should be relatively simple to prevent a power-off-dodges-destructive-action attack, by simply making the operation (incrementing and storing the attempt counter, checking the password) an atomic operation.

So they would still get 10 bites at the cherry, and sure, on the tenth, they could depower the phone and prevent the wipe, but if each attempt is persistently stored before the password-check is carried out, depowering the phone wouldn't give them any more chances.