Yes, a phone can still be tracked even after a factory reset if certain tracking features or software are enabled. For instance, services like google's Find My Device or Apple's Find My iphone can continue to locate a device if the account is still linked and the device is connected to the internet. However, if the tracking apps are disabled and the phone is removed from the associated accounts before resetting, tracking becomes much more difficult. Additionally, law enforcement may have methods to track devices regardless of resets.
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