GS:The NPD Group's monthly sales reports do not factor in digital content, and this has led some, including Electronic Arts, to shrug off the firm's findings. Today, however, the research group released the results of its Q3 2012 Games Market Dynamics U.S. report, revealing digital spend in the United States alone accounted for $1.4 billion from July-September.
I used to work at a video game retail store, and we would often have free things in our inventory, and we could "sell" them to customers to get them out. And I know these are download, so there is no inventory, but at the same time. It's just a 100% off discount. So from my educated guess I would say they count.