When you are in a 3DS firmware without the web browser and you update from a game cart the web browser will not be present. So, how to solve it ? I tested it in a 7.1.0 firmware without the web browser and it was perfectly working thanks to Nintendo very good firmware update function (it did not brick my console even if I removed the battery almost 15-20 times !!!). DANGEROUS!DANGEROUS!DANGEROUS! This method can potentially brick your console because you are going to remove the battery while the system is updating !!! DANGEROUS!DANGEROUS!DANGEROUS! 1 - do an online system update and look VERY CAREFULLY to the progression bar; probably each step forward in this progression bar is something installed so, again, LOOK CAREFULLY at the progress bar and remove the battery at each progression step/notch you see (in my experience I waited each 3-4 progression "notch" before removing the battery to save some time but my system was updating from 7.1.0 to 9.6 [I suppose] so it was downloading quite a lot of stuff); 2 - after each battery removal restart your 3DS (hoping it will reboot again!); 3 - if the menu with the web browser got updated the console power-on will be a little more longer and you will see a message saying that the sytem menu is booting and to not turn off the console ! 4 - when the menu appears you will have your functional browser without the system update (I am still at 7.1.0) !!! EDIT: the title should be changed to "above 4.5", the forum removed the > character I used.