[fluidcruft]

I think they're speaking about system dumps at the manufacturer level.

For example, I'm fairly confident that the data on Motorola devices can be read completely using USB from bootloader mode without any data modification (using tools like RSD Lite or sbf_flash). By itself that wouldn't get past OS-level encryption, though. That bootloader is entirely Motorola's with functionality and communication protocols dating back to before the pre-Android razr flip phones (from what I could tell back when I was doing battle with the XT720).

On the other hand, passphrases for boot security on mobile devices are often extremely weak (pin or what-have-you) and easy to brute force (assuming there is a backdoor to access the TPM contents or whatever it's called on ARM/OMAP/etc if it uses that sort of thing)