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It can be done, they just have to follow the Microsoft service model..

They already have 2 level of services, normal and plus.
With the new generation they can drop some services from the normal free one. For example, trophies can only be uploaded for plus users, ingame chat can only be used by plus users, etc.
Add some additional services exclusively to plus users.

Then let the players choose, they will not be technically denying online gaming to anyone and can use it as a hook to sell consoles, but the normal service will be so basic that most people will be willing to pay for the plus service.