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I'm guessing that 2.36 contains a large amount of changes to PS3's OS. 2.40 was properly build based off the 2.36 build and as such SONY is properly using 2.36 to achieve two things.

1) Find out any problems that 2.36 could create ...
2) Provide a reason to hold back on 2.40 for a week or so.

Oh and does anyone remember the FW update ratchet and clank came with? I believe within a day or two of r&c being released SONY released another update... that basically means 2.40 could be released at any point in time...