A post on the developer's support site reads:
"We have received some 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."
"Primary reports seem to be that updating to firmware 3.61 will cause PlayStations to overheat. There have been various reports of this on a few different games now, all reporting their PS3s turning off or 'Red Lighting' after having installed 3.61.
"This can range from games randomly freezing to PS3s turning off anywhere between 30 mins use to two hours. We have confirmed locally that multiple games (Rockstar and non-Rockstar) overheat or freeze only when 3.61 is installed."
While Rockstar is carrying out an internal investigation, it’s asking anyone affected by any issues since the update to contact Sony support direct and not the Rockstar helpline.