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I don't think there's a payload for 8.1. However, if there is a Japanese game with between 9.3 and 10.3 he could update, then get a copy of a Jpn OoT, load the save using another 3DS and use that to get into HBL and downgrade.Isn't it possible otherwise to boot rxTools's Devmode and sysupdater using OoT since he has OoT and another hacked 3DS ? Not sure what firmware versions oot3dhax is compatible with.