Just my 2 cents but yesterday I was at Best Buy and looking at there dvds I did notice a steelbook movie. I think it was a horror movie but it could have been sci fi, anyway it wasn't sealed with celaphane. It did have the factory tape on the top and side proving that the dvd was never opened.
I remember thinking someone pulled a fast one on BB and opened, watched it and returned it, but then I saw 2 more copies of the same film exactly the same way. No celaphane wrapping, just the tape. Odd