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There hasn't even been a handheld to outsell even old generation Nintendo handhelds yet.

If you split up GameBoy and GameBoy Colour then it's about half and half I think, which means the PSP may surpass one of them by the end of it's life.

As for your question, I'm sure it will happen sometime, but I can't forsee a situation where it will in the immediate (10 years) future.... and in ten years time I imagine I could add a further 10 years of foresight to say it probably won't happen.