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The author was taking about new machines that had been returned and refurbished and sold on the Apple web site with full warranty and Apple backing. He didn't state this clearly.

Machines that are leased for 3 years before being refurbished are sold at a much bigger savings, but without the warranty (unless the seller provides one).

Like you I initially thought the author was recommending the older pre-used machines rather than ones that were refurbished for quality control reasons and not because they necessarily needed it.