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A 720p display would be enough considering the size of the screen, going 1080p wouldn't even be really noticeable -or at all - for most people.

So my take is: stay on 720p and focus on delivering the exact same performance than the docked counterpart, just with a smaller resolution. Also, Nintendo should ensure to try and make dips below 720p a very rare occurrence, as that's much more visually disturbing than being at 720p in general for the handheld part.