Can a stolen French release iPhone be tracked by its GPS signal? Even if the thief unlocks it?

Can a stolen French release iPhone be tracked by its GPS signal? Even if the thief unlocks it?

Of course, if the theif has the passcode to unlock it, he/she can simply disable mobile me or any other tracking app installed.
Bottom line is, that unless you:
a) had mobileme's find-my-iPhone (or other tracking software) installed and activated before the theft,
b) had a passcodee on the phone so the theif cannot simple go in and change anything they want
c) the theif keeps the phone turned on and is somewhere with a data connection active
there is no way to track it.

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