Only because it's multi platform. Halo 3 sold $170 million on the 360 alone.
$310 million across two systems for GTA IV.
If Halo 3 had sold the same amount on two systems it would be...
$340 million.
Gears of War 2 is going to be a 360 exclusive so it's not going to beat GTA IV (nothing probably will for a long time) but it may come close to Halo 3.
More products are sold when they are available to more people.
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