No, the "new" one that I removed had it's spring in the proper position.
There was no discernible failure point with the seal that I could see.
The guys at my local Subaru dealer say they rarely see axle seals fail and suspect it might be something else.
I wonder how tight the diameter tolerance of the axle is? In other words, if the bearing surface has been refinished during the remanufacturing process, could it's diameter be just a hair too small to seal correctly? When I test fit the seal before installation, it seemed to fit over the axle snugly.
The other variable in this equation is that the wheel bearing on the affected axle was also recently changed, right around the time when the leak began. I used a Timken bearing from Rock Auto and not a Subaru part, and gave it to the dealer to install as I don't have a shop press. The tech at the Subaru dealer said it fit correctly, but I wonder if somehow this has an effect on the oil leak. Just throwing that out there.