Not counting the games that involve just beating the game (unless it has a twist to it "beat it under some hours") or by pressing Start or watching a cut scene. I'm talking about the ones where you put good amount of game time just to get that one achievement for what its worth.
I'd probably say Marathon Man in Halo 3 for 40 Gamerpoints. It probbably takes about an hour or two to complete for an easy 40 points.
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