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The 3DS sold 3.3m units last December. For it to win 2014 it needs to match those 2013 sales, needs the PS4 to not widen the current gap, and then for the PS4 to sell only 1.6m units in December (for context, the PS3 managed almost 1.2m units last year, its 8th December).

I'd certainly put the odds in the PS4's favor :p