I paid a couple of grand below invoice on my 2011, so it's possible. I also ordered my 2011 not sure if that helped or not.
My other tip would be request information/register on jeep.com, fill out the form and tell them you are in the market, after I did this they mailed me a few rebate offers for $750, I also attended the Rocks n Road event last year and they sent me a $750 rebate code after that.
Past Jeep: 2000 Grand Cherokee Ltd, 2007 Wrangler Unlimited Sahara
Current Jeep: 2011 Wrangler Unlimited Rubicon