In Camera HDR vs Software HDR

[broonster]

I'm looking to buy a new digital SLR and I quite like the Pentax K-X because it has in-built HDR (only 3 exposures though). However, on reading a review of the camera it says that when shooting in HDR you basically have to use a tripod every time as the in-built HDR doesn't cope very well with any camera movement during the HDR exposures. If any movement does takes place it results in soft final results.

Is this also the case for HDR when applied in a software package (for example PS CS5) or does the software handle the images being slightly off-set if there is any camera movement during bracketing?

Cheers
C