By marking them as refurbs Microsoft maintains the market value of the remaining stock.
If they sell them as new for $200 then no one is going to ever want to pay more than $200 for a new one again. People in this very thread are complaining that the 32GB bundle is $250 when it was $200 a couple weeks ago.
That makes the assumption that first off these "Manufacturer Certified" is actually Microsoft, which isn't completely clear. It could even be a microsoft certified merchant or something like that, which wouldn't really feel compelled to do something solely for the purpose of protecting microsoft's bottom line.
It also makes the assumption that a random ebay merchant selling a bunch of them for a certain price (mainly to SDers) would significantly affect the entire Surface RT market. This post and the previous one aren't the Touchpad firesale. Its not advertised everywhere by Microsoft, and its not at all retailers (B&M or online). As someone in this very thread said, people who got in on the last deal were successful at reselling their Surfaces for $300+ on ebay (when they go for $350 new from anywhere). There are still plenty of non-SDers willing to pay a little less than retail, in spite of thousands being sold by this ebay merchant.
When he sells a quarter of a million units or even a hundred thousand units, then I might agree with you. Right now though, I doubt this will significantly put a dent in their market.
"Inna ma'al ousri yousra"
(94:6) - "Verily in any hardship there is ease."
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