Hm. That, too, could be off if Apple starts dropping the "Mac OS" moniker completely and calls their OS versions ONLY after the codenames.
Back on topic: Really, the requirement of installing the newest firmware is very clearly stated in the ReadMes and the manual that comes with OS X. It's not like they're hiding anything.
Plus: OS 9.1 is NOT a requirement for installing OS X, since you can install OS X on a computer without any kind of operating system on it (i.e. a clean harddrive). So should they make a _big_ message that reads "Install firmware first!" on the package, the install media as well as the software installer? Should they do big messages for ANYthing a user could do wrong? No: They create a manual for that. And ReadMe files. Etc.
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