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Oh, as it turns out, 38 million is exactly what the GameCube shipped in the FY from April 2002 to April 03. In other words, Nintendo is suggesting a low software sales as those of the GameCube. 

It is really not - at all - an optimistic projection. Compared to te hardware number, it's downright ridiculous. If they meet their hardware projections, they'll blow past the software projection, possibly by more than 10 million. 

Source for the GC numbers: http://www.vgchartz.com/article/3035/big-4-videogame-hw-amp-sw-shipments-from-1983-to-2009and-beyond/