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Well, yeah, it's possible. Though this doesn't include something like World of Warcraft (nobody knows how much that's sold) or other games digitally distributed, Nintendo can dominate VGC's list.

14 PS2 - Grand Theft Auto: San Andreas Rockstar Games  18.16
16 Pokémon Diamond / Pearl Version Nintendo  17.36
17 Mario Kart DS Nintendo  17.35
23 Brain Age 2: More Training in Minutes a Day Nintendo  14.60 (outside shot)
25 Wii Sports Resort Nintendo  12.81

I left out the ones that will pass it up. On top of this will be NSMB Wii, Pokemon HG/SS, Wii Fit+. This brings San Andreas down to #21, so Nintendo needs 5 more 20 million sellers before 3rd parties come up with any. It's definitely possible.