Only wave of bricks I've heard of/read about involved installing a Korean system update on non-Korean Wiis, yet the Wiis received the notification to update because their regions had been changed.
To add to the actual discussion, though, they could probably find a way if they really wanted to. Either through the already mentioned file re-naming, stability update, or what have you. Honestly (without getting into the piracy discussion) I don't think it's worth their time, since the best way to do it seems to be a new hardware revision (but it'd be silly naming it the new new 3ds

).