Mmm.. that's pretty unlikely in reality, especially given the 200 times/sec channel hopping that (most) GSM systems utilize, on top of the PSK modulation and code spreading.
TDMA with a 4.615ms time slot will give you ~217Hz and if you pump that out at 0.5W then you're going to hear it on anything with an amp that isn't shielded/filtered against this.
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