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I only think it'd count if they're both into it, or she's at least tolerant of his gaming habits. It wouldn't be quality time so much if it was her watching him level grind in Final Fantasy or something.
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This is exactly what I was thinking. There really has to be a lot of in-game interaction with your partner or else it's just stupid and worthless. Games like 2P Guitar Hero, Mario Kart or Street Fighter (if she's into that kinda shit) will undoubtedly provide more enjoyment of the other's company than "LOL WANNA WATCH ME BEAT SEPHIROTH?? ONE WINGED ANGEL HUT HUT HUT HUT HUT HUT HUT!!1"
More in-game interaction = more out-of-game enjoyment.
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The wonderful thing about it is, it makes for plenty of sexual innuendos, and if no matter who beats the tar out of who (if its a versus game), the angry make-up sex later will be great.
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AWESOME.
Jam it back in, in the dark.