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Ten million, whole being an awesome achievement, is a harder topic to discuss in this way than 20mm. If switch goes on to sell a hundred million units, which it looks likely to do, there is a good chance that there will be some 10 million tellers that we can't possibly even think about right now. New IPs, possibly even something third party could pull it off.

The 20mm threshold is basically reserved for established Nintendo IP. Ten is a lot easier to pull off.