The difference is resources. PSN games generally use static contained environments. Even with BR-D games like Virtua Tennis and NBA, the game is restricted to a static court. This is why these types of games were the first to achieve high frame rate at 1080p.
Before believing 1440p resolutions are possible for PS3 games, you should probably wait to see a fair percentage of games running at 1080p/60fps. If even 1 out of 10 releases achieve this in the near future, I'll be satisfied.
Designing games for a 1440p native render is a weak sell for 1440p displays, but not the other way around. Virtually no one will go out and buy a 60" 1440p display for several thousand dollars to play PSN games on their PS3. Even if BR-D movies are produced at 1440p resolution, it would still be a niche market for the well to do or those with muddled priorities who live on credit.
Only after 1080p becomes industry standard.
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