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In Japan, if you buy two 3DS games between today and January 13, you can get a third for free. However, you must select the downloadable freebie from a list of fourteen titles, which you can view here. No word yet if this campaign will be extended outside Japan.
DISCUSSION
Didn't we technically just get this offer with the SMT/Fire Emblem $30 e-Shop credit? I would be very surprised if this offer came over here.