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The thing to consider is that they'll start making the game about 2 years before it comes out and that's when they'll make the decision on platform, so the difference after 2 years is what matters

But frankly, they are so similar I just don't think they'll bother unless there is a giant gap

I think it will be something like PS4 20-25m and Xbox 15-20m in 2 years, nothing near the requirement

If it was something like 30m PS4 and 10m Xbox, then maybe some smaller devs won't bother with Xbox, but I doubt it