From MCV is this artical.....
UPDATED: Rockstar says that latest firmware is causing some older consoles to freeze or switch off
Sony's 3.61 firmware patch for PS3 - which was released as parts of its efforts to plug the gaps caused by the PSN breach - may be bricking older machines.
That's the claim of a customer services rep at developer Rockstar. The statement was made in reply to claims that users playing LA Noire on their consoles are suffering freezing issues.