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Any guaranteed brand new OLED Vita will have 3.60 or lower on it. This is because Sony stopped production on OLED Vita's for the US before 3.61+ released. If you get a 3.61+ OLED Vita, it's because the seller opened it and updated the firmware/it's not brand new.So Red / Silver Jpn and any PCH2006 is a no go? I see so many people posting about the new vita they ordered and wondering if it does or does not come with 3.60 or not, then they get it buy don't even come back and be like hey here is my result. I have asked so many ebay sellers about the FW and so far none used have lower then 3.60 so I plan to buy a new one and see both black and blue slims, jpn and usa in 2000 and 2006. Fingers crossed.
For Slim Vita's, the same is generally true for any US version. So long as it's brand new, you're fine. JP units, on the other hand, are still being manufactured. While most older JP colors should have 3.60 or lower, it is possible you might end up with one with a higher firmware. IMO, it's probably best to stick with US Vita's first and foremost, unless they end up being way too expensive vs a JP alternative.
Not 100% sure on EU Vita's, but AFAIK it should be a similar case as the US ones.