No.
If any console manufacturer wanted to do a memory upgrade (Nintendo), the RAM pack expansion for the N64 shows it simply resulted in a split in the installed user base. Nintendo resorted to packing the RAM pack with one or two of the only games that actually required the additional memory after the upgrade was released.
The easier solution is to do a hardware refresh; no upgrade options for older models. Then you're left with a New 3DS and either another split in the installed user base, or a hardware upgrade that the vast majority of developers aren't going to utilize because they want their game playable on the entire installed user base.

























