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has anyone seem an application form sony to the patent or trademark or whatever office they need to apply to in order for them to legally introduce a new sku? i remember people finding out about the 40g model that way a few weeks before the actual announcement.

There was one... back in December, I think. There was some discussion about what it might be.

This new model probably won't be out until spring though, since that's the vague launch window for the DS3. There'll be plenty of time for a new FCC filing by then.