I believe the confusion comes from Apple’s use of the Mac App Store for both 
software updates and Mac apps and updates, which are technically delivered 
through two different pipelines.

Here is how it works: you don’t need an Apple ID just to get software updates 
for installed software, i.e. the operating system, or any Apple applications 
that are not installed through the Mac App Store.  However, you *do* need an 
Apple ID to download any app or its updates from the Mac App Store, which 
includes the apps Apple uses to install newer versions of the operating system, 
any the newest versions of preinstalled apps that now come with Macs.

So, in other words: if software updates are simply updates to things already on 
your system, then no.  If updates or apps are from the Mac App Store, including 
major new releases of Mac OS X or the iLife and iWork suite, then yes.

To answer your question, therefore, you do not need an Apple ID to update a 
Snow Leopard system.

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