Electronics Stolen from Checked Baggage: Is There Any Recourse?

FlyerTalk member platinumPizza had a brand-new Apple IPhone 4 stolen!! 🙁 It was at the bottom of a checked bag while traveling to Europe, but it was gone. The mobile telephone was purchased with an American Express card.

The American Express Purchase Protection reportedly does not cover theft of items in baggage not under one’s direct supervision. Because the baggage was checked at the time of the alleged crime, does platinumPizza have any recourse, especially since the incident happened two weeks prior?