If it wiped the key that's a different story but i wonder how high the trial and error count is, if it was really low we'd have complains from people that their data was lost.This happens all the time - if you hook your iPhone up to a corporate exchange server, it'll generally be set to wipe after 10 incorrect pin codes.
One of my coworkers lost the contents of their phone multiple times in the space of a week when their young kid got ahold of the phone and enter random pin codes. I've also had drunk friends at the bar wipe various phones this way.
Wonder what it looks like when you don't use a code (like me), is the HD just encrypted with a void code made of zero or does it change the key size? or is it not encrypted at all? Don't care about my phone security at all but makes me curious.