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It really depends on how long they let this generation drag out.
I mean, this is what, year 9 for the 360? That's still not quite at 85 million yet (or at least I don't think so).
That being said, if this generation lasts 7-8 years for both, the X1 could potentially do it, though I would personally think it will fall somewhere between 60-70.

PS4, I have no doubt will pass it, probably stop at around the 120 million mark would be my guess.

Just my guesses though, so if people think I'm wrong (which I'm sure they will) I won't be offended :)