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If you mean ROM chips by flash based memory (there is actually a huge difference between those 2, even though they get confused all the time), I say yes. Real flash chips would be too expensive but ROM chips are very cheap to produce once it's set up.

@Tachikoma: It might very well be so. Looking at the diagram for the patent application, I see both internal and external HDD, so I don't see what use the memory card could have other than being the medium the physical games would be delivered on.