Apple released a new firmware update to address user complaints about a battery drain issue with the Apple AirPods Max. The new firmware update, 3C39, was released without any notes but is meant to address the endurance problem have faced with the AirPods Max.
There have been many user complaints of battery drain while connected or while using the Smart Case. Another issue users have been reporting is with connectivity when using AirPods Max with a Mac.
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Hopefully, this new version of the AirPods Max firmware will address user's concerns about these issues. Apple being Apple, they don't make it easy to update the AirPods to new firmware versions manually. Apple says the new firmware versions will install when the AirPods are connected via Bluetooth to your iPhone.
If you're not sure if your AirPods Max has been updated, check to make sure you're using firmware version 3C39. If not, you can check by going into the Settings app on your iPhone and then navigate to the Bluetooth menu. Once there, find your AirPods Max within the connected devices list and then tap the "i" next to your AirPods Max.
It should tell you which firmware version you're using. If it's not 3C93, I suggest make sure the AirPods Max are properly paired with your iPhone as they should receive the update automatically when paired.