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He will lose.

1) There is no way he can prove FW 3.0 killed his PS3 instead of wear and tear
2) The update asks you to digitally sign an agreement that SONY are not responsible for damages resulting from the FW update.
3) It is easy for SONY to prove what FW 3.0's issues were (they are documented) AND for SONY to show PS3 hardware failures being within reasonable limits (only figures i have are under 0.5% failure rate for the UK according to SONY)