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They will only do it if the result is cheap, durable, and desirable.

let me elaborate:

Cheap:
They don't have to be as cheap as blu-rays. The people who release digital-only are not actually worried about the disc-prices themselves anymore. It's the whole logistics nightmare involved that jack up the costs nowadays. The publishers who can afford to release physical could conceivably afford paying 5-10 times the price of a disc. If you buy LOTS of 32GB flash memory banks, the price will be reasonable, and you get all the benefits the medium has over optical storage.

Durable:
The games cannot be flimsy little pieces of shit like a regular flash-memory card. It's have to be built into somethign that won't snap in half and won't get lost under your nail like an SD micro. However, adding more plastic housing will jack up material, production, and transportation prices. There's a lot of tough decisions to be made if they go down this road.

Desirable:
They have to be sure that people would find it neat. Mimicking the NES cartridges would appeal to nostalgia, but would jack up production price with all the plastic and the space it would take up.
Trying to hit something closer to Game Boy/Nintendo DS would create confusion as to weather the games were really meant for a home console.
Getting it closer in size to SNES/Famicom/SuperFamicom might work, if they could make it look modern with a vibe of classiness that would appeal to both oldtimers and new players.


Anyway, that's my thoughts on it. I wouldn't rule it out as a good idea, but I'm fairly certain Nintendo won't do it.