Believe me....both of them were brand new.
If I had to speculate, I think they probably started making new ones because the refurbs were becoming so undependable. A perfect example is a new connect I did last Friday. Customer called Monday, complete signal loss. It WAS the H3, replaced it today and all is good. I bet the one I installed on Friday had been RA'd for signal loss issues BUT, it was an on again, off again issue.
I always held my breath when I opened up a refurb here at the store because there was a decent chance it was going to be DOA, OR go bad during the first month. I actually started dreading a Dish sale because the problem got so bad. When you are booked several days out, it is a REAL pain in the butt to have to deal with a defective receiver.