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From Kotaku:

Wedbush Morgan analyst always seems like such a mundane title when dealing with the master of video game precognizance that is Michael Pachter. Speaking with Shacknews, the Pachtman puts forth the possibility that Rockstar Games founders Sam and Dan Houser could very well slip from under Take-Two Interactive's wing once their contracts come up in February 2009, much like Bungie jumped from Microsoft. It all comes down to money.

"I don't think that this is an issue of dissatisfaction with Take-Two; rather, I think it is rational to believe that in the wake of the $850 million Pandemic/BioWare deal, high quality developers like Bungie and [Rockstar] North would look to test their market value"

How much do you think a company like Microsoft or Sony would be willing to pay to secure Rockstar's exclusive service? How much would you pay? What if we threw in the magic of Pancake Puffs?

There have been rumors of Sony buying up R* in the past, and given R*'s history with the company (GTA, Bully, etc.), and current exclusivity deals (L.A Noire, unannounced new IP for ps3), I could see Sony picking them up in the future, especially if the ps3 is still in a dismal 3rd place come 2009. Sony also has a history of buying out studios (Eveolution Studios being the most recent), or contracting them out as 2nd party (Ninja Theory, Media Molecule).  However, Sony would probably buy out R* if they did anything, as they usually only make small, fledgling studios 2nd party, providing thm with support and publishing their games.

I could see Microsoft possibly contracting them out as 2nd party, but definitely not making them 1st party. MS seems to favor signing exclusivity contracts with independent studios or taking up the role as publisher rather then buying the studio outright. They've been publishing games for Bizarre Studios, BioWare, and the like for years, yet they don't seem to mind letting them get bought up by other, larger developers. They even let Bungie go, who knows why.