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 Consent based extraction means that the owner of the device provided consent to extract the device by providing their password to unlock the phone. No OS can't protect against someone willing to do that obviously, so it's out of our scope. 
 Got it, I thought this was a report about a new attack, it is just denying some misinformation flying around that I haven't seen anyway. 🤷

Still, its cool to see that once again, GrapheneOS is 10 steps ahead everyone in the game.

So for other devices, there is nothing to prevent brute force cracking but for Graphene (and pixel 6+) the secure element slows the attack down. Is that correct? 
 The secure element is the core piece that protects against brute force attacks and physical attacks. It is what enforces brute force throttling and also makes tampering far more difficult. We also use it for other features like in Auditor.

It is a hardware requirement of GrapheneOS to have one and for the device to support an alternative OS using it. That is one of several reasons we use Pixels and this note is an example of the benefit. 
 If someone wanted to brute force a device that is BFU, they need to exploit that secure element in addition, rather than just the phone. Very old Pixels we do not support anymore have secure element exploits as per the Cellebrite documentation.