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Signalstar said:

What about all of the indie VR games that release on PlayStation that will never see the light of day on Xbox or Switch? Don't they count?

That's an interesting point.  It's not that they do (or don't count), it's that it's essentially a different platform.  A bit like whether 32X and/or Sega CD games should count when considering the Sega Genesis library.  Reasonable people could disagree on whether they count or not.  :)