Probably refurbished 900's actually, which is fair.
My experience:
If a phone is physically damaged - warranty is voided and insurance kicks in. If Asurion or whomever the provider is has no stock you are generally offered a comparable model if not the exact model brand new. I got the Incredible towards the end of its life cycle with Verizon and folks were talking about the Incredible 2. The Incredible 2 came out and I admit I was a bit jealous of the more refined design. I broke my phone, paid the insurance claim and took advantage of the brand new Incredible 2 insurance replacement.
Do I suggest people do this? No.
However, if your phone is damaged it should be replaced. Granted, if they have Lumia 900's it should be the Lumia 900. If they are out, it shouldn't be a Titan 2 or a Samsung Focus. If they went that route it might as well be a Pantec Burst or a Nokia 3360.
I won't damage my phone again for the purpose of getting an upgrade:
1) My Lumia works 100% out of the box.
2) My Lumia was just recently unlocked - why would I give that up?
3) I got a cyan one and it is blemish free.