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I can't remember which thread it was in but The Source mentioned something about Nintendo announcing 2010 full year financial projections some time in the early or middle part of May i.e. ~6 weeks from now.

If the 3DS is to be released this year it would have to be factored into these projections so obviously Nintendo couldn't wait until E3 to announce it and didn't want the first announcement of their new system to be a mere footnote in a financial report.