Is a patching system possible for the DS?

I had a thought earlier while in the shower about an idea I had for the DS game system.

Does anyone think it would be possible for a WiFi system for a game to be made where the player can link up to WiFi and download patches for the game that has the system?

For example: This type of system would make it possible for DS Total Online games to be possible, because it'd allow the developers to add new content to the game through the patching system.

But, again, would this be possible?

Or does the limited data of the cartage make this impossible?

What do you think?

[So many "possibles" XD]

it'd be increasingly possible with the DSi, considering the SD Card slot.

Downloadable content is possible with the DSi afaik