He is assuming that, because all the other endpoints had buggy rate-limits, this one would too, and they also fixed it.
This is a bad assumption to make, because the device passcode recovery flow is going through an iCloud Keychain HSM cluster, which is a completely different implementation from everything else (which are just web services). In fact, it is well-documented that Apple cannot update the underlying code of their HSM clusters, as they destroy the management cards after initial provisioning. So they can't have actually fixed this bug if it existed prior to his report. That code was surely audited much more carefully, and depends on a much smaller technology stack, than all the web service stuff, and certainly handles rate-limiting within the HSM itself.
So I have no reason to believe that this flow was vulnerable to the rate limit bypass race condition like the others.
However, we have a different problem now.
I called it the iCloud Keychain HSM cluster because, as documented, that whole thing is used for iCloud Keychain escrow (i.e. password store in the cloud). That's an opt-in feature. More info here:
https://support.apple.com/guide/security/escrow-security-for...
I did not know this, but apparently if your account has 2FA, the code used for this is indeed your device passcode, which smells dodgy to me:
https://support.apple.com/en-am/guide/security/secdeb202947/...
But still, the context is iCloud Keychain.
But now Apple are claiming this flow, which does not have the problem OP discovered, is used for all Apple accounts that have logged in from a passcode-protected iOS device. This implies that they are re-using this system, originally designed for the very narrow use case of (and trade-offs that necessarily come with) iCloud Keychain, as a general account recovery mechanism for all Apple accounts. That does, in fact, mean that they have (the ability to brute-force) the device passcode of everyone who has ever logged in their device.
That's bad. The HSM cluster stuff makes this hard, but it is a huge change in attack surface. It means that your device data security now not only depends on on-device software and hardware design (and Apple are famously good at this), but also the security of an HSM cluster at Apple HQ. It means that if you manage to break into a given HSM cluster, you can then brute force the passcodes for all users managed by it. And it means that if the HSMs have a vulnerability, that is a massive liability. The HSMs are third-party, and I honestly trust HSM manufacturers much less than Apple themselves when it comes to building secure systems.
So I would very much like to know what's going on here, whether that flow really does work on all accounts regardless of whether you use iCloud Keychain or not, and why none of this is documented in the Platform Security Guide. Does the hard 10-attempt limit used for iCloud Keychain escrow recovery also apply here, or can you continue trying PIN codes forever subject only to rate-limiting? Is this the same codebase or a different one? There are many questions here, and Apple's vague answers and lack of documentation for this make it sound like something very fishy is going on here.