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my kobo resets to firmware 1.9.14 (I think I have that right). This definitely doesn't need an online registration to use sideloaded epubs. Around the whole 1.9.17 disappearing top margin debacle I went through a a few cycles of factory resets and updating (largely because 1.9.14 doesn't have the wifi drivers) and would often not register so I wan't prompted to upgrade again.
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