BoyGeniusReports claims that they have seen an internal AT&T memo referencing refurbished iPhones for only $199 (4GB) and $249 (8GB). These are to be unadvertised specials, however, and only in special regions:
Refurbished iPhones will only be available to purchase in select COR stores across the Northeast Region and will be available while supplies last. Please reach out to customers that have recently purchased an iPhone to see if they are interested in activating an additional iPhone at a discounted equipment cost. Please note no in-store sales materials should be created. This is to be sold as a closing tool only.
So, it may be difficult to find out where these deals might be.
BoyGeniusReport's track record on rumors has been mixed (Jay Z at Macworld), though we have no reason to doubt the authenticity of this memo.
Confirmed: Several readers report they were able to get these refurbished phones.