Nope, they're just CLONING the games. With the region lock in it.This is what I thought too, the ability to flash generic chips would allow them to bypass the region lock too
The Region Lock is part of the game (probably resides in the header, I must admit I haven't exactly studied the 3DS's inner workings yet), and it can't be modified without being able to change values in the RAM on the fly or a complete re-signing of the game code.
Bootlegging is a "dumb" science, they can't change anything.