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If it has to be one of those 3, then I would probably say Smash followed by Fit and Kart close together, though Kart will eventually sell more, and has the best shot at 15 mil.

The other game that could make it (home consoles) is GTA4 if combined, though it certainly won't manage it seperately.... so the best chance at 10 million on a specific console is GT5, but it's a slim chance.

Not sure about CoD4 combined, that seems to be still selling well.