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Mario Kart and Animal Crossing are both going to be 35-40m sellers at least. I can see Smash crawling its way there if the Switch 2 doesn't drop before 2024 (and there's a third set of DLC), Pokemon Sw/Sh could do it but given their current legs I think they will likely top out at ~25-27.5m (again, assuming there's no more DLC and there's a mainline release next year to replace them). BOTW will top out at ~25m once BOTW2 comes and cuts its legs, Odyssey will finish around 22.5-23m (again, I think Odyssey 2 will come and cut its legs in 2021-22).

Future releases that could get there:
- If there's Pokemon gen 4 remakes next year with new features (like a Wild Area and the inclusion of new Pokemon etc.) I could see it possibly getting there.
- A gen IX that takes all the good things about Sw/Sh and fixes their issues could do it too.
- A Tomodachi Life game could definitely do it too given the huge audience overlap with Animal Crossing and potential memeability.