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Today I learnt that you can have a maximum of 3000 photos on your 3DS's SD card
(lemmy.blahaj.zone)
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Oh huh, the Switch has something similar... You can't have more than 1,000 videos or 10,000 photos on a micro SD, or 100 videos and 1,000 photos on internal memory.
I'm not exactly sure why, but I bet it has something to do with how it keeps track of them