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Squilliam said:

#1: Microsoft sold more Xbox 360 consoles than Sony sold PS3s.

#2: Retailers likely sold more Sony PS3 consoles than Microsoft Xbox 360s.

Technically #1 is more correct, however usually #1/#2 both go the same way so most of the time they are interchangeable. 

It was kind of obvious for Microsoft to make that statement as they were likely shipping straight to retail in 2010 due to supply constraints and they needed to catch up on stocking so some of what ought to have been 2010 shipments were 2011 shipments. This is why they were able to claim they sold the most and make it the truth.

 

 

This is the most plausible explanation. It don't really matters who sold more, it's a tiny difference that only fuels fanboy wars.