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Bofferbrauer2 said:
I'd say it will be more difficult at this point not to reach or pass those 10 10M sellers

2 are already well on their way (SMP and Splatoon 2), with NSMBUD potentially also breaking that number if it sells steadily over time.

2 Games coming out this year which should do it without much fuss (Pokemon and Animal Crossing), with Fire Emblem possibly also passing that number over time if it's very well recieved.

Next, among third party games, Minecraft should be able to reach that if it continues selling steadily, same could potentially go for Stardew Valley, Rocket League and some other Indies which always seem to be on top of the monthly download lists.

Finally, there's the question if free-to-start games like Fortnite count. If they do, then Fortnite and possibly Paladins could do it, too

Nah, free top play doesn't count as downloading something for free is not a '"sale".