LaserSailor

There is also a distinction between 'gate checked items' and 'checked luggage'

The former are just property, and is not covered under the carriage of contract - even if the airline loses it, it is functionally equivalent to leaving your Ipad in the seat pocket.

Speaking from experience on DL....

See post above - evidence that once an airline issues a gate check, even for gate checked cabin luggage on regionals, it becomes checked luggage and the airline is liable for loss per standard rules.