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It'll be tough. It would almost have to be a new Mario like mentioned above or a brand new game that hasn't caused major boosts. We've seen Youkai Watch just get released and not boost the system even though it sold 700K opening week. Everyone who wanted that game essentially already had a 3DS.

I'm thinking new Mario is honestly the only thing at this point, there is 20M 3DS's out there already. I also like that DS trade in option.