Mike Wall, in writing about the Mars Rover update, notes this:
The MSL team calls the flight software that guided this daring touchdown R9. With Curiosity now safely on the surface, it’s time to switch over to R10, which was uploaded during the rover’s eight-month interplanetary cruise.
Uploaded to the rover, while in space, on the way to Mars. That is one hell of a OTA update if you ask me. Especially when you consider the trouble Google is having just keeping Android users on the latest version of their OS while on Earth.