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I can see it happening, 3DS is really starting to slow up in sales and Wii U hasn't shown any recovery despite a number of 'system sellers' that have been released to no effect.

If 3DS peaks at 80 mil and Wii U at 20 mil,then PS4 at > 100 mil will get it there, and to be honest I can see PS4 doing that. I don't think it'll sell much over 100 mil, but it will beat it, IMO.