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TheSource said:

The holiday bundles for 360 add 5-10m units of sw which NPD would not count in the attach ratio.

360 has a base of 2m-3m units or so in Americas regions outside the USA which probably adds 10-15m.

The rest of it is just different ideas about legs I'd say.

If I add 10 and 15 million to NPD's total (so your high end estimation) I still only get around 140 million copies of software sold, which is still a discrepancy of 30 million. And NPD might even track more titles which only makes the gap larger.