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Yes most contract phones do require a credit check, but there are some that don't. And Sprint PCS (even though I am not crazy about their overall service) has a very lenient credit check. Trust me, I know, I used to sell their service... and people who were unable to get a little regional provider because of bad credit were able to get Sprint. Then there's also pre-paid plans which don't require any credit check. And then at the very least, like someone mentioned, there's always just having a phone with no service connected to it because you can at least dial 911.
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