L.A. Noire and the new firmware 3.61. The post has since been removed, though a new announcement has been posted on Rockstar's website providing some clarification.
The company notes that it has "received a very small number of customer support questions about PS3's overheating or shutting down while playing L.A. Noire." It adds that "Rockstar Games and Sony can confirm that neither L.A. Noire or firmware update 3.61 are causing the PS3 hardware to overheat," though no solution is offered.
The company advises that those with such problems contact either Rockstar or Sony technical support.
Update: It appears that Rockstar has also received complaints of crashing or freezing issues on both PS3 and Xbox 360. Rockstar has outlined steps to help correct the problem. Find them after the break.