That is probably a typo in the second case since it's unusual to down grade to upgrade. In my experience at least.
Probably, whoever wrote the release notes got confused with this (from the download page):
If your system's current BIOS version is 0037 or earlier:
1. You must first update to version 0039.
2. Then update to the transition version 0099.
3. Finally you can update to 0104 or later.