Only sort of. There is still an internal SD card for those who have the skills to work with partitions and filesystems, or can follow instructions created by someone else. Because of this, it gives Kobo users the ability to expand the non-volatile memory or to recover their bricked device.

Yeah, it's very user hostile. That's particularly true for people who want to store large libraries on their Kobo. On the other hand, it is useful for those of us who are buying a Kobo reader because it is a (relatively) open device.