Overkill on Halo 3 wasn't easy due to its "right place @ the right time" nature. Also Key to the City on GTA IV, whilst not overly hard took a long time. Presently doing Insane Mode on GoW2, and grinding down Seriously 2.0. They're not that easy either :D
Mile High Club on CoD4, well, i haven't got it. I've tried, but no cigar!
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