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Famously The Tesco Hudl Tablet's Server was turned off when it still wasn't very only and then a reset bricked it.
I think in the case of Kobo they are saying that if the Factory Reset FW is too old then you can't register via WiFi (because protocol too outdated). But you can still select Connect to PC instead and then either edit so you don't need to register, or update FW or use Kobo desktop program.
It's not the same as being bricked.
There may also be adverts for some, but it does also seem to be about updating TLS version.
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