Version 5.x and later images accept only signed binary files, which improves security on the Cisco IP Phone 7960 and 7940. The use of signed binary files does not allow you to return to an earlier software version. Once a Version 5.0 firmware image is installed, for instance, regardless of protocol, it cannot be replaced with any previous version.
http://www.cisco.com/en/US/products/sw/voicesw/ps4967/products_upgrade_guides09186a008022a968.html#wp1046332
You can downgrade to any other signed image
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