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I think most iPhone users don't know how to actually turn their phone off.
They think pressing the power button so the screen goes black (and the clicking sound) is "turning off" the device.
This is what I do all the time, I know it hasn't been turned off but I make sure it's in flight mode before I do it.
Not strictly speaking kosher but I think nearly every iPhone on an aircraft is "turned off" the same way.