OK, I changed the third point in my post to be a bit clearer.
If you want to allow real SD cards to be used, you will need to move the files. But, Kobo doesn't seem to be putting external slots in the new devices, that might not be worth worrying about. Or write to the real card and let the user eject and insert it to process the books.
The other thing to consider is what happens when you connect to a PC. Will the device present the correct drives? Will calibre be able to find the books?
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