I've got games I haven't played from the sale before THAT. Basically, every time I swear to myself that I'm not going to buy any more games till I've made my backlog disappear, I find an irresistible sale on some game that I know I want, but not necessarily bad enough to play it right away.
For my purposes, I consider any game I haven't played for at least 1 hour per $1 of purchase price to be unplayed... I guess that's why even if I see Duke Nukem for $5 I can safely say "I shouldn't have too much trouble playing that for 5 hours" and then I play for an hour and think "oh God, it's worse than I imagined it was".
So yeah... uh.. did you want an actual game count? ugh... I have about 85 games that I've never or barely ever played. :I --- http://raptr.com/badge/dc821beb3ce7e522d4d6721ba24c11e0/fs.png http://myanimelist.net/signature/arleas.png
Only have five games on Steam that I have not played yet and none of them are from this past sale - they are all from prior sales or games that came with other ones (CS:S from the Orange Box, The Witcher, Saints Row 2, and Star Wars Battlefront 2 as an extra included with another game).
However, I have more console games still in their wrapper than PC games unplayed. With my new job, I have very little free time during the work week working 17+ hours a day and my days off I devote to hanging out with friends and my girlfriend. I believe last I checked, I have games ranging back to God of War 3, Gears of War 3, inFamous 2, Dark Souls, etc. that still remain unopened simply for the fact I know how engrossing most of those games are and I just don't have the time. --- Wolfdale e8400 @ 3.6GHz OC'd | 4GB Mushkin RAM | eVGA GTX 260 896MB VRAM 576/1242/1998 OC'd to 732/1457/2360