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Is there plenty room for improvement? Of course.

Will Nintendo use the most current in 3D displays in a $100 BOM device when it becomes available? No. The tech used in the current Sharp sourced parallax barrier display was commercially available back in 2005. http://www.theregister.co.uk/2004/08/12/3d_illusion/.

That's how long it took to become a high production yield, portable, low res display, sourced for an estimated $33.80 per unit. http://hothardware.com/News/Nintendo-3DS-BOM-Estimated-to-be-10071-iSuppli/

The 3D component of the 3DS' biggest advantage seems to be that of marketing more than anything else. It's an effect that has yet to be used in any 3DS game so effectively that it plays better with the effect on than off. As much as I'm entertained by the effect (I keep it on all the time), it's clearly not what's selling the device to mass consumers (price and games spurred sales first). Sourcing a more expensive panel in the interest of showing the public an "improved" 3D effect probably wouldn't be the best business decision.

On the other hand, a larger display (3DS XL) using a larger version of the current panel, would probably hold appeal to the same consumers who bought the XL although only Nintendo's bean counters know whether that particular variant made them enough money and sold enough units to warrant its release.

If Nintendo can source a better display later down its production life cycle for the same or even less, then I don't personally see why they wouldn't, but until such a panel exists, there's not much point right now in entertaining the thought.