Factory systems don't really come with the browser until they are updated, and game cart updates don't count. This person will need to either get cubic ninja/oot or update to 10.7 and attempt the downgrade to 9.2
EDIT: wait yeah, even if they got CN/OoT they'd have to downgrade anyway. just update i guess
factory systems do come with a browser...? they always do. the only exceptions are 1.0.0/1.1.0 consoles, and 8.1.0-0J New3DS systems.
You can't use the N3DS Browser without updating the firmware?
ever since 9.9.0-26, the browser has an update nag. also, game cards containing 9.9.0+ contain a dummy browser that replaces it with nothing but a message.
this nag can be bypassed by setting the date back to 01/01/2000 and resetting browser data. each time you close the browser, you have to reset it again. once the date turns to January 2, set it back.
if it looks like this, it's a dummy browser and you can't use it.
if it looks like this, it's a real browser that's been blocked and you can bypass it.