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Yeah I think that's a very good prediction. It's hard to tell. On one hand, the userbase is smaller. On the other hand, there's probably more hype for this game, and both companies will be pushing it through bundles or price cuts and advertisements. 11 million is definitely possible, and very probable.

Though zackblue, 25 million would be crazy, since even GTA:SA was short of that by 10 million.

My predictions would be about 11 million. 6 million on 360, 5 million on PS3. I won't break down into regions.