I'm planning to get a 3DS this week and while the $40 gift card with $200 XL at Target deal seems tempting, this seems like a viable alternative for those that would rather just pay $31 less up front. It also comes with a free game of your choice, but they're trash reject games so I did not include that as a selling point in the topic title. I suppose Cooking Mama isn't bad though.
In addition, for $10 more you can have the Mario and Luigi Dream Team limited edition XL with dream team built in for $179. Something to think about.