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I think the only games that you can make a case that it's not really 60 fps are Link's Awakening and Echoes of Wisdom.

The rest... I mean there's dips here and there but 99% of the time they hit their targets. To insinuate something like Smash Ultimate is not a 60 fps game because it has drops if you use 8 ice climbers in one stage is just insane lol