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Uh, that wouldn't make much sense. Theoretically I could buy and sell the same copy a million times, and it'd be a million seller.

The best sellers would probably be the hyped games that are relatively disappointing, or games without much replayability. It'd be no different from including all game rentals. I don't see why it'd be meaningful to include these - if the person doesn't want to keep the game, it didn't deserve another sale.