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Now, I've never played Halo 3, so I'm not too familiar with why it deserved the award over the Orange Box or Wii, but apparently Edge seems to think it does:

Edge said:
Ultimately it is the integration and coherence of Halo 3?s online content that makes the game stand apart. From its Theater mode to Forge, and the way a party playing through Live can seamlessly manoeuvre between them, here is an experience that demonstrates an unparalleled understanding of the potential for console online play.
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