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Will be hard

If quality and variety would matter in this Gen the 360 wouldn't even stand a chance but...

The US is crazy about their yearly Halo and CoD(its technically a 360 exclusive)
Microsoft is already starting their banwaves before Halo 4 even gets released...The next wave is around the CoD Release.This means around 5 Million consoles alone aka 30 Million DIFFERENT people have a 360 but they sold like 70 Million ;)
The whole thing depends on Europe and Japan - I think Tales of Xillia 2 and some other games will push the numbers a little bit even if the WiiU is probably hurting Sony a lot there.
It really depends on Europe at the end where even CoD is selling stronger on the PS3 than on the 360.

But well who cares - We know which consoles and games  stand for quality and variety in genres and would deserve 20 Million sold units for each of its unique exclusives =)