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Short answer: no.The 3.5 and 3.9 updates strictly consisted of updated material and contributions by 3rd party developers: Amiga International did not own the end product in any way whatsoever. Big chunks of 3.5/3.9 came from the publisher Haage & Partner, who chose not to continue further product development after the 3.9 release. This is also part of the reason why there is none of the Haage & Partner developed code in the OS 4 release.