An item on Rockstar Games’ support site about PlayStation 3 systems shutting down while playing L.A. Noire pegged the 3.61 firmware update as the cause of the problems. That support page has since been pulled, raising the question of whether that really is the source of such issues.
Before it was removed, it said the issue primarily happened with older, 60GB and 80GB models of the PlayStation 3, and that systems were either overheating or beeping three times before turning themselves off. Noting that reports indicate that the 3.61 firmware causes PS3s to overheat, the support page stated, “We have confirmed locally that multiple games (Rockstar and non-Rockstar) overheat or freeze only when 3.61 is installed.” That doesn’t sound like the sort of claim that’s thrown out there lightly; it’s not phrased in a way that raises it as a possibility.
It also said, “At this time we are recommending contacting Sony directly to report the overheating issue. However, this is not the end of our support; we are continuing to test L.A. Noire on all firmware versions and hardware models to isolate the issues and see what can be done. As always, we will update this article as soon as we have updates.”