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I have several arguments in defense of GTA: SA:

First, it makes more sense to count multiple platforms for SA as all versions are direct ports, unlike SMB3 (obviously counting Mario All-Stars is ridiculous).

Second, you only counted PS2 and Xbox versions of SA, not PC (or the trilogy releases).

Third, and by far the most important: regardless of sales, GTA: SA claims the moral victory by being an infinitely superior game on every level. Hell, the frickin' mini-games in SA are more complex than Mario's 2D outings.

But I guess since this is a sales site, that argument is not gonna hold a lot of water... and will likely get me a lot of abuse from pre-teens and Peter Pan-types.