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Not in an FPS, but for a simple game like a 2D RTS or TBS it might be possible. 64 is kinda stretching it for what you'd expect from an RTS, that's a lot of connections for that kind of game. In a text chat it's definitely possible, IRC works on DS just fine. All in all anything is possible as long as the total bandwidth is below the max the DS can handle, and with an FPS where everyone moves around everywhere and shoots everything, it's nearly impossible to fit 64 or even 16 players on something with such a low bandwidth bottleneck as the DS.
We can always dream... I'm patiently dreaming for the next-generation handheld from Nintendo which could possibly support 802.11g (which would then support loads of players).
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