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It's really dependent on a number of issues -- MS's continued pressure to keep 360 sales strong (360 == 2nd), BluRay's acceptance actually meeting analyst predictions (360 == 3rd). WW sales will eventually start to affect available NA software in a big way, so unless the 360 can really keep up in Europe as well, they may fall back in NA much faster than they have been, over time.

I think there's a good chance the 360 could finish 2nd, this gen. I wouldn't say its "safe to assume" by a longshot though. It's not.