They seem to be hung up on bundled time being "bonus / upaid time". Funny because phones with time are typically more expensive, but hey, I suppose I technically did not buy a plan.
I disagree: you did buy a plan, a bundled one.
That's pretty much the point of filing an FCC complaint: it leaves Tracfone in the position of explaining to the FCC why a plan that you paid for as part of a bundle is not a plan that you paid for. My thought: since Tracfone's already been under a consent decree once over failure to meet their claims about unlocking phones, they might decide to take the easy path, and unlock it.
IIRC, someone on Howard Forums had trouble unlocking their bundle because they had changed their phone number. So the unlocking system mis-counted their days of service. From what I recall, it all ended well and the phone was successfully unlocked.
Any chance your phone had some similar history that could have triggered the unlocking problems?