I bet the owner forgot to include the frame in the locking job. Just that 
one time. Just by mistake. And an opportunist walked by. No way would a 
thief "defeat" a u-lock, then lock it back up all neat and tidy. 
I have forgotten to include the frame in the lock once in the last couple 
of hundred times I've "locked" my bike... it happens occasionally. 

Glad he got his bike back.

Edwin

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