The problem with filing an unpaid item case is that you are signaling that you would like the buyer to pay. You shouldn't relist until you are certain that the buyer won't pay. I've had plenty of cases where the buyer paid after a few days - no internet service, completely missed the messages to pay, etc.. Tough decision during Christmas shopping - you really don't want to miss a sale because of the process, so some might have just cancelled and relisted, rather than take through the eBay process. I don't necessarily endorse this practice.