No. Because the bootloader is locked there's no way to fool Google TV into loading alternate images. Therefore, it is dependent on built-in update mechanism which only goes forward not backwards. I suppose if you can convince to manufacturer to spoof a 2.1 firmware as an newer image than what is out now that would allow everyone to go back. However, chances of that happening is pretty slim to non-existent.
I hope someone comes out with a hack bac to 2.1, 3.1 is just crap . 2.1 worked very well for my needs , How did everyone rollback the driver to 2.1 when 3.1 was in beta ?