Just had to do a BIOS update with MSI's M-Flash BIOS utility and needed a fat32 formatted USB key. This is how to do it with diskpart
Commands in an Administrative Terminal
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 | diskpart list disk select disk 2 rem (or whichever is your USB key) rem Important don't get the select disk command wrong the next command wipes the entire drive clean create part primary select part 1 format fs=fat32 quick |

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