Update 2: Sony and Rockstar Games have issued the following joint statement.
"We have received a very small number of customer support questions about PS3s overheating or shutting down while playing L.A. Noire. At this time, Rockstar Games and Sony can confirm that neither L.A. Noire or firmware update 3.61 are causing the PS3 hardware to overheat. We are both committed to working hard to find solutions to this and any issues that may arise. If you are experiencing any issues with L.A. Noire or your PS3 hardware, please contact technical support using any of the means provided below:
Rockstar Support
Rockstar Support on Twitter
PlayStation 3 Support"
Update 1: A Sony spokesperson has told EDGE that the firmware 3.61 is not responsible for L.A. Noire overheating issues. Sony also went on to say that "Rockstar have now updated their FAQ on the matter, have admitted that it is a fault with their latest title LA Noire and have offered a work around. It should also be noted that the issue with this title is not PS3 specific and is also affecting other consoles."
Rockstar Support is advising affected users to delete their game data (not their save data) from their PS3 or clear their cache on Xbox 360. Rockstar are currently describing such incidents as "isolated crashes."
Original Story: Sony's 3.61 firmware patch for the PS3, which attempted to secure consoles after the PSN breach, could be making older machines freeze or switch off.
This claim originated on an official Rockstar support page. However, this page has since been taken down, and Rockstar have stressed that this was not an official statement. The information was sourced by a member of their customer support team from the European PlayStation boards.
When the page was active, Rockstar support detailed "reports of PS3s overheating while playing L.A. Noire or beeping three times before shutting down/turning themselves off, mostly on older 60GB and 80GB fat models."
And that it was "confirmed locally that multiple games (Rockstar and non-Rockstar) overheat or freeze only when 3.61 is installed."
Again, Rockstar have stressed that this was not an official statement. When contacted for comment, Sony said, "We don't comment on rumours or speculation about our products."