There should be an award handed out for misleading titles.
Pseudo journalists love them, sites fishing for hits love them, bloggers fishing for traffic love them and posters looking to attract attention to their threads love them too.
While it's hardly a contested opinion that the 3DS is pretty lacking in titles currently, it's a new system, barring Japan it's been out for less than a quarter and it more or less gets a free pass in this respect until the holiday season, at which point it is "do or die" as there won't be any excuse for releasing a new handheld without at least a couple must buy titles to sell the platform within its first year of release.
Whether flagging soft sales result in third party publishers abandoning the platform is beyond speculation at this point since very little has even been released.