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CFW is normally a permanent fix as its written and can be saved over the standard and is completeOh, Pong... I think you just answered your own question. It's a firmware, it's not the standard one, it's been modified so it's custom.
where Modified firmware is the same with more changes made but not a permanent firmware complete
like when you download a PS3 custom firmware, its a complete firmware file that replaces the existing
psp is only a patch but it is flashed to the system making a full custom firmware
when you download a gateway update its just over 1mb (no where near a full 3ds firmware)
its just patches the exploit runs on the firmware
(once we have firmware running from the SD card nand dump, thats custom as its stored elsewhere but loads it in its entirety)