Well. That's not how I read it. First. The EFF asked for renewal of the ruling on behalf of its clients, being:
The Wireless Alliance,
ReCellular and
Flipswap. All three used handset stores, and commercial entities. And they asked for it because the digital lock made it harder, if not impossible for them to sell recycled handsets... without risking DMCA related lawsuits. And this is what The Copyright Office had to say about it:
"
The DMCA shouldn't be used to interfere with recyclers who want to extend the useful life of a handset."
And that also clears the sky for commercial unlockers, who may do the work for you, because not being able to do the unlocking yourself... shouldn't prevent you from unlocking your phone.
Now have a look at this:
"
The Copyright Office agrees with EFF that the DMCA shouldn't be used as a barrier to prevent people who purchase phones from keeping those phones when they change carriers."
Note the "
when they change carriers" in it. That to me sounds [suspiciously] like you
first have to fulfill your contract [for a subsidized phone]. As in you used AT&T [as provider] and want to switch to another provider, while keeping your handset... but
after you fulfilled your contract with AT&T. Which to me sounds reasonable.
I might be wrong, but this is how I read it.