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These are pretty much all sold through. It would have been really easy to move these units on discount even 3-4 years later. Even if they're returned wholesale, customers can get their hands on them eventually through those wholesale retailers. Those ARE copies in consumer hands, though not *technically* sold at retail.

So maybe VGC isn't wrong for their retail number but Nintendo's is more accurate.

By Nintendo's numbers VGC has also undertracked B/W, reported at 15.58 million, not 14.79. That's 800K under.
HG/SS is 12.72 million, not 11.63 million. That's a massive 1.1 million under.