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Duke Nukem already has several side-scrollers... '3D' was actually the third installment, and a popular naming convention at the time (many games with two 2D installments developed a third in 3D) to make a double entendre of the '3' suffix).

Yes, I know, but I mean: outside of 1, 2 and GBC, the only one that felt remotely close to 3D was Manhattan Project, and that was still 2.5D.