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It's simple...
If you start an update using an almost exhausted battery AND a configuration which does not charge your reader while connected via USB, power may run out during the update. This indeed may lead to a dead device.
Sony does not know about the cables you use, about any USB hubs involved - they simply are too lazy to explain every different situation.
So they just say: "Charge it fully" and they're out of liability.
The Reader will update even at the lowest charge IF the configuration is correct (charging while connected). The instructions just make sure it will work even in a worst case scenario.
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