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I'm going to invent two scenarios, for the opposite situations.

 

Minimum - 22 million

  • Nintendo releases their next handheld as early as Holiday 2015, and 3DS sales then plummet quickly in Japan, much like DS sales have after the 3DS came out in Japan.
  • Games like Kirby Triple Deluxe, Super Smash Bros 4 3DS, etc do poorly on the 3DS, moving little hardware or software.
  • Unconfirmed games, like Monster Hunter 5, Dragon Quest 11, etc, are released on other platforms, possibly as exclusives.
  • Future emphasis at Nintendo is shifted towards the console market, helping the Wii U but hurting the 3DS.
  • Consoles make a comeback in Japan.
  • Sony gets serious about supporting the Vita, releasing major games that appeal to the Japanese audience.
  • Ends up doing somewhat better than the PSP lifetime, but below the PS2, Game Boy, and DS.

 

Maximum - 37 million

  • The Next big Nintendo handheld is released no sooner than mid-2017, and the 3DS decently sells through Holiday 2019, ala the PS2 in the early 7th generation.
  • This means games like Pokemon G7, Super Mario 3D Land 2, etc, all become major 3DS titles.
  • Also, more time for notable redesigns, especially since a DSi-style redesign has not happened yet.
  • Games like Kirby, Super Smash Bros 4 3DS, etc. do well on the 3DS, promoting more sales of software and hardware.
  • Game like Monster Hunter 5, Dragon Quest 11, etc end up as 3DS exclusives.
  • Previously non-Nintendo titles like FF7 get 3DS releases in some form, even if simply as a digital download.
  • Console development in Japan continues to falter in favor of handheld development.
  • Sony goes bankrupt by the end of 2015, or otherwise gets a weaker handheld gaming division, weakening the competition.
  • As the 3DS becomes increasingly popular, it gets an eShop on par with the stores of many mobile devices.
  • Price of hardware eventually falls under about $100 for basic unit during supported life.
  • Becomes the best-selling gaming hardware of all time in Japan.

 

Personally, I find both of these options unlikely.