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I might have misunderstood what you meant, but.. The consoles that has a minimum firmware higher than 3.55, such as 3.60... Even if E3 or someone else suddenly releases a CFW at version 3.60 or 3.70, who knows, they won't be able to downgrade anyway, though their minimum firmware version is 3.60 or 3.70.
Sony's newer revision to the metaloader (it is referred to as metldr.2 if you wanna googlexpand your knowledge) that they incorporated in newer PS3s after they were exploited, blocks downgrading.
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