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Start at -20 dbFS pink noise = 79 db. Same as TV/DVD post.
If your publisher/developer complains, fight the good fight and inch it down bit by bit (78, 77, 76, etc.) as needed. I got my last game out at 75 db reference level and it is/was quieter than a lot of games but it sounded just fine in the end. Also pick out blockbuster games that have a decently referenced mix and use them as examples in your arguments (Gears of War and Halo come to mind).
-Dave
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