I believe the secure enclave, which is responsible for mapping the passcode to an encryption key, has hardware level rate limiting so I suspect GrayKey is limited by that.
Ay my shop we didn't actually have a ton of success with graykey because most the devices were BFU. Once the agent is loaded, you can plug the phone into a regular charger and let it brute force itself into the next millenia. But after it tries te first few hundred passcodes, the rate drops significantly.
I have a password the maximum length allowed so it's not trivial to unlock when she does that.
I suspect most of these reports come from either bugs in the software (and some quick Googling suggests this has been the case), or perhaps that even someone (heck, even a savvy child) was trying using some sort of brute force exploit to unlock the phone.