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I was thinking about this yesterday, and if you knew how to pull it off, this would probably work.
Basically, you use packet injection to fool Sony's servers that your PS3 is at the current FW. How could this be done?
For starters you will need the right packets, which would be the ones that your PS3 sends back to Sony to confirm what FW you have. You will need to acquire packets that confirm that a PS3 is up to date. So you will probably need a second PS3 that is on the current FW. (so you can get the 'I am up to date" packets.)
You would probably have to create a program to automate this, cause with packets I am pretty sure timing is important.
1. You turn on your PS3, it makes a connection to Sony.
2. Sony sends the FW check request
3. You block your PS3 from sending the answer packet to Sony.
4. Packet Inject the "I am up to date" packet(s) back to Sony (this is where the automated program comes in).
Then after that I guess Sony might send a "Ok, you can now log in" request or something like that.
Obviously this is far from any detailed tut or anything remotely close... but people who know how to do this kind fo stuff should be able to understand the concept.
The one barrier that might put a stop to this is if the packets expire or are console specific. In the event the packets expire (or need to be correctly dated), the program you create would have to automatically modify the packet(s) to include the right times so the Sony server would accept it as real.
Seems far fetched and probably not possible for most of us to pull off, but this idea could work in the right hands.