FIFY. It's not known at this point that it was stolen. Also pretty sure you can't prove Gizmodo knew it was stolen at the time that they bought it. Even if it's proven that the initial person stole the phone, it's a separate legal issue entirely to say in hindsight that they knowingly bought a stolen phone. And the fact that they began machinations to return it before the raid tells me that while their intentions may not have been entirely benevolent, they weren't ...er...larcenic? Felonial? Theft-oriented. I believe there's a statute of limitations involved here, but I'm not a lawyer, and neither are you.