It seems as though some of the PS3 dev kits at E3 were having some serious problems in that they were crashing often. In fact GamersReports is reporting that firmware updates for the dev kits were being sent out every 2 hours by Sony to try and alleviate the problem.
According to an Activision employee we [...]
"PS3 Dev Kits Struggling at E3" - 15.05.06