This article seems under-informed. The scenario which privacy and security wonks usually consider to be the explanation for various government assertions that they can track phones while they're off is that the target's phone receives an OTA firmware update which makes it act as if it is off (turns off the display, etc.) but does not actually power down the phone's radio. So, yes, the phone is "not really off", but as far as the user can tell it is off.<p>A link for context: <a href="http://www.schneier.com/blog/archives/2006/12/remotely_eavesd_1.html" rel="nofollow">http://www.schneier.com/blog/archives/2006/12/remotely_eaves...</a>