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Usually they come in blank packaging, so presumably they’re returns.
Though they never have any marks or scratches to indicate a human has ever touched them, so it’s hard to tell what they are. Maybe they have an amazing cleaning system.
(I did buy once an airport base station that hadn’t been 100% reset and you could see the previous user’s name)
Aren’t the refurbs often just new old stock of previous models no longer sold in the Apple Stores?