Cell phones can still be tracked even if the GPS/location tracker is turned off. I believe that is why the writer also included "obsolete flip phones." However, he is wrong to use "some" because all phones that are turned on can be tracked. Cell companies, and by extension intelligence agencies, can triangulate your location using phone towers. It is actually easier (or was easier) to track someone using the network because you don't need a warrant, and until recently you needed a warrant to track someone with GPS. The Supreme Court ruled in 2012 that police needed a warrant to track suspects using car GPS device. However it seems that the Fifth Circuit has ruled that the 2012 Supreme Court ruling did not apply to phones.
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