Gaming Firmware update w/o internet connection

Hachibei

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Hi everyone,

Is it possible to update the 3DS' firmware without a wireless internet connection? I've heard that new games will come with the latest firmware built-in (at the time of their release, most likely), but are there any other alternatives?

EDIT: TBH, all these answers suck and it doesn't seem like an ACTUAL answer will come up anytime soon, so I'm just gonna give it to the one guy that actually sounds like he knows what he's talking about.
 
Solution
@ nitrozz: LOL. Remember Animal Crossing Wii? 20MB. Probably same deal with a lot of 3DS games. I think Ninty can fit the FW updates onto 1.98GB of space.

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