Got my LR AWD on Thursday and of course it was V9. I found somewhere here people saying that you must wait, but there was another post claiming that if you schedule a service appointment they will push the update to you. That's exactly what I did. Last night I scheduled a service appointment and first thing this morning I got a call to let me know that the firmware update has been pushed to my car, so the appointment is not needed anymore and has been cancelled. Spent the 25 minutes in the car around noon time and got the update over Tesla's LTE network. It is 32.12.2. Yes smart summon is here!!!
Bottom line - if your car is still new, you don't have to wait to get your V10, just schedule an appointment and they will push the update to your car.