Some iPhones ship without SIM card (or with improperly seated SIM card), will not activate
Lack of a SIM card, or an improperly seated SIM card can block activation.
[Posted Friday, June 29th]
We purchased an iPhone 8GB today (after waiting in line at the local AT&T store for about 8 hours), only to find that once home and opened, the device lacked a SIM card. iTunes and the phone both displayed a message indicating that no valid, unlocked SIM card was inserted, and that the card is required for activation. Our iPhone lacked both a SIM card and a SIM card tray.
Read more at our sister site, iPhone AtlasResources
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