Are modern movements resilient to date changes during the “danger zone” hours ~9PM-3AM?

Curious

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The instructions that come with NH35's still warn against it.

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My understanding is that instant date change movements (2824, SW200, etc.) are less prone to damage at those times, but why take a chance? 

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Unless that modern movement is a circuit board, nope. Some movements, especially those with a day date function are more prone than others.