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In some cases it's less expensive to buy a subsidized phone on contract then break the contract and pay the ETF than it is to buy an unlocked phone at full price.
AT&T will unlock a phone once the contract is fulfilled, or sometimes after six months if you tell them you’re moving to an area with no service or are traveling abroad.
On the other hand, CDMA phones (Verizon and Sprint) do not have SIM cards, and they rely on databases of Electronic Serial Numbers (ESN) to determine if the phone is one of theirs. They will refuse to activate it if it’s not one of theirs or if it has been reported lost or stolen.
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