Yes. That's why it's best, if you're going to sell cryptocoins on ebay, to send the buyer a physical paper wallet through the mail with a tracking number attached. That way, if a non-delivery dispute happens to come up at some point, you can give paypal the tracking number to prove to them that it was indeed delivered. Paypal likes physical stuff. So if you can prove that whatever it is was indeed a physical item (and paper wallets do count as physical items) that was delivered to the buyer, chances are the dispute is much more likely to go in your favor.