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I'm guessing it will still need to be able to place calls out of the box, at least to 911. That was the case with the 1st gen iPhone. Is it an FCC requirement that all phones be able to reach emergency services whether they're currently active or not?

And it would be able to.
AFAIK 1.1.4 can make calls. The new modem version obviously comes pre-installed just like the 1st one did.
 
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