Fish has claimed 40,000 in the past. Part of this I suspect is developer time and expensises simply for the cirtifiication not MS fees. For a small company with limited number of employees you cant deligate the certification tasks and result in a delay in developling a new game as people are diverted for the certification process. It is an unfortunate situation but part of the cost and hassle is to punish unfinished games. It hasn't stopped the big game companies from constant day one patches.
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