Quoted from LTG:I don't think you can copy a micro SD card and use it on another micro SD card to update a different game.
If it's like JJP's ISO update, the card may need to be configured to be bootable. Still, a card that updates one game should work on others, unless CGC has deliberately configured it to erase the update from the card upon completion as some form of copy protection. OTOH it may also create a flag file on the card to show an update has been run, in case people leave the card installed in the game by mistake.