My New 3DS XL is on the newest firmware but I installed Luma, Arm9, Hourglass, and IronHax before updating it. I know updates block flash carts but I'd think you could use CFW to get around it. I just need to pick a good model. The only thing I need is a cart able to run original Nintendo DS games, bells and whistles aren't that important. Right now I'm eyeing the R4i models but I thought I'd consult the forums before I spent money on one.