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Best android phone (GSM) under 200 dollars?

Hi all,

I need your opinion on this one... What's the best android phone under 200 dollars?
It has to be GSM. My aunt intends to use it in europe, with a sim card she'll get over there. Even if the phone is locked I understand most phones can be unlocked (for a fee of course).
My best guess is I have to look for phones from T-Mobile or AT&T.
I have the LG Optimus T on TMobile, with CM7 (from mik_os) and I really like it. That one falls within this price range, but I wonder if there's any other phone out there that will fit the bill, maybe with a bigger screen or resolution?

Any comments or ideas are welcome.

Thanks.
 

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