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I suppose anything is possible, but I don't think it is very likely.

Yes, American audiences don't seem to love the 3DS as much as the DS, but the Vita is doing so poorly in sales I can't imagine it will leapfrog the 3DS. Both will probably lose sales in North America, but Vita will lose more.

A new Zelda game and some 3DS Pokemon games will keep 3DS going strong in the years to come.