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So 52 vs 40.
Tri Force Heroes, Super Mystery Dungeon, Paper Jam, Fire Emblem Fates, and the eventual Pokemon Z will make it 45.
Then Twilight Princess HD, Star Fox Zero, Xenoblade Chronicles X, and Zelda Wii U will make it 49. Plus, some other titles that are already out that I think will leg it out to 1 million.
For 3DS:
Sonic Generations
Dragon Quest VIII
and PilotWings Resort I think will make it 52.
Than for Wii U.
ZombiU and Bayonetta 2 will make it 54.
So in the end, I say 3DS+Wii U million sellers > GBA+GC million sellers.