Well let's look at the possibilities.
They have 4 games right now that are out, or coming out in Japan that are guaranteed to sell 1 million copies, some maybe even first week.
Fire Emblem Fates, Youkai Watch Busters, Youkai Watch 3, and Animal Crossing Happy Home Designer.
Which brings their total to 42
Anything with the word "Pokemon" on it is guaranteed to sell 1 million minimum.
And I still believe we will get ONE more Pokemon RPG before Nintendo calls it quits with the 3DS, so Pokemon Z or X2/Y2 is easily going to crack it. Which brings the total to 43.
There are some games that haven't cracked 1 million yet, but will get there eventually. These games I believe are Fantasy Life and Sonic Generations. So 45.
Also, just like Pokemon, anything that has the word "Mario" in it will sell 1 million copies. So Mario & Luigi: Paper Jam can be added to the list. 46.
I want to say the same thing for anything with the words "Legend of Zelda", though I have my doubts about Tri Force Heroes. Not in terms of quality, I think it's going to be a damn fine game. But the last Zelda game that had multiplayer didn't fair so well in terms of sales for Legend of Zelda standards... but that game was on the GameCube, and this is the 3DS, which has already more than doubled lifetime GameCube sales... Yeah sure I'll give it the benefit of the doubt. So 47.
But I have even bigger doubts for Bravely Second. Even though the first game managed to crack the 1 million barrier, it came out at a time when the 3DS was at its peak & was considered the king of gaming, now that it's on its way out, I'm not to sure.... But, since the first one was so well received and has an established fan base, along with a higher install base to work with... I'll give it the benefit as well, but I think it'll take some good legs.
So 48.
And that's all I can confidently predict at the moment. Even then it needs 9 more games if all of the above turns out true. Plus, there are still PSP games that are around that barrier and still being tracked, so the number of PSP million sellers is likely to increase.
We'll just have to wait and see.
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