Because Walmart had that sale (then BestBuy/Sears followed), Toshiba had nothing to do with it. Should we not count units sold on sale?
Saying Toshiba had nothing to do with it is like saying Disney had nothing to do with it when Amazon has the BD sales. If you honestly think Toshiba wasn't a key enabler in those sales, well, quite simply you are mistaken. And you can be sure that Best Buy and Sears wouldn't have followed suit if it was their margins that were being cut by $100 dollars on the players; Toshiba obviously green-lighted the move.
And to your question (I could do without the roll-eyes by the way) - of course we should count units sold on sale... but the consternation here seems to be about when BD movies go on sale that it's skewing, whereas when HD DVD players go on sale it's just... a sale. Either they're both "just sales," or they're both just "skewing," but personally I'm tired of pick-and-choose viewpoints where one is maligned and the other has a halo.
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