eBay
If the early termination fee wasn't so punitive, people could 'buy' a phone at the huge discount, terminate the contract and then sell the 'never used' phone on eBay or some other venue and possibly make a profit on the transaction. I haven't done the numbers (not interested enough), but if there was even a little gain to be made, an enterprising college student could enlist all his/her friends to buy phones, terminate and then sell them over to our entrepreneur so that a goodly amount of beer money could be made.
Seems like a fee as high as the one mentioned in this article would surely prevent someone gaming them that way.
BTW, I'm not a supporter of VZW or any other carrier. IMO they are all getting obscene prices for very little value provided. I have an antique phone that <gasp> just lets me dial numbers and talk to people. Quaint, don't you think?