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It depends on the settings of the iPhone.

If the passcode lock was not enabled on the iPhone prior to it being stolen, then it is very likely that the data can be accessed.

If the passcode lock was enabled, it is unlikely the information will be successfully accessed - someone would have to enter the correct passcode in order to do so.

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Q: Is it possible to access the data on an iPhone that has been reported stolen and already deactivated by ATT?
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