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A factory reset erases the file system, but on most Android tablets, the physical data remains partially present on the NAND memory until it is overwritten by new data.
On iPads, encryption is recreated during a reset, and previous data becomes inaccessible — recovery without an iCloud backup is then very difficult.
For Android tablets that have undergone a reset, the more the device is used after the reset, the lower the chances of recovery. In the lab, direct memory chip extraction (chip-off) offers the best chance of recovering partial or complete data.