Rating: 4.9/5 Stars (2,209 reviews)
Price: $10 - $50
Buy it: Amazon
Sometimes the best gift is the gift of choice. Perhaps the person you are buying for this season is picky beyond reason and usually unhappy with whatever game they are gifted.
Then ditch the headaches and complaints, and just go with an eShop card so they can purchase whatever game they want. They'll thank you for giving them the freedom to make their own decision.