Can you provide a link to a written source?
I only can find Nintendo of America
VS
UBERCHIPS
and Nintendo of America
VS
ANXCHIP, AXIOGAME, FLASHCARDA, MOD3DSCARDS, NX-CARD, SXFLASHCARD, TXSWITCH and USACHIPSS
It's not like they have a magical hat to pull out exploits from.
If there's no (known) bug in the firmware of the switch that can be triggered in software, you're basically forced to use a modchip.