There are many ways.....I have imported a JP n3ds and mistakenly updated it to 10.5 but there is a way to downgrade it now back to 9.1. I have succeeded doing that yesterday, it's not hard and it only takes me one try with no errors. If you want to play the games you don't have to get a JP 3DS as you can just install cfw and get the cia files from other websites, but if you feel you want to support Nintendo JP like me, then sure.