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Zekkyou said:
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

Then that's probably the answer right there. 

I see no reason why the 3DS would sell significantly more units in 2014 than it did in 2013.

Someone mentioned product dumping, but this is Nintendo. Their business model remains based upon generating profit on every unit sold, so there's not going to be any ridiculous manufacturer's discounts to clear out a product line. 

It pretty much goes without saying that the PS4 will move more than 1.6m units in December unless SCE completely fumbles production and distribution heading into that month.