Time locked. They did the same in thing in the demo. Game Freak has also repeated over and over they will never release DLCs.
But there isn't any data for the Brains. It's not there.
And I've always found Gamefreaks policy towards DLC weird and dumb. They won't release something akin to the Battle Frontier over the internet (something that pretty much everyone has access to), but they'll make me drive to Gamestop (something that not everyone has access to) to get myself a code to get multiple Pokemon, in a series known for needing to "catch them all?"
Gamefreak can suck it.