Hardware 3DS Firmware and DS Wi-Fi Connection

BORODA

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Hello.
I own a 3DS XL on 4.5 firmware and don't want to update for known reason. I also got one of those million R4i clones floating around. The question is, can I block firmware update using parental controls and use DS wi-fi connection (assuming i have an unprotected access point) to go online? Or it will still require a latest 3ds firmware?
 

BORODA

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Bump on the question.
Also, what do I need to block on parental controls to stop updates from happening?
 
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