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It is possible that Nintendo could have sent out development kits for their next handheld even if it wasn't expected to be released until 2011 ... and if the development kits have only been sent out very recently it would be likely.

Its fairly safe to assume that new Nintendo hardware would be powerful enough to support ports from the Gamecube (and possibly the Wii), which means that some developers might want 12 to 24 months to develop games for the system before Nintendo released it.