You gotta remember that there are system apps, so take away 10 spaces.
Also, there's not a set number of 3DS games. I install different regions sometimes, like for Fire Emblem Fates, Animal Crossing and Smash.
I have 54 retail games, I swear most of them are first party save for Cubic Nina, Resident Evil, two Rayman games, and Michael Jackson: The Experience 3D. ......
I also have other random loose games, like four regions of Smash (US, JP, EU, and the Special Demo)
After that, 48 3DS download software. Same as above, the only bad ones would be...Fluidity: Spin Cycle, some Japanese Club Nintendo Picross games, and every free game on eShop.
THEN, 42 homebrew apps and utilities, stuff like CIAngel, FreeShop and its updaters, Luma3DS Updater, Smash-Selector, an FTP server, Homebrew Launcher/Browser, and pretty much every soon-to-be useful app like 3DSident and MultiDownload.
DSiWare. I have around 12 of them.
The entire RetroArch emulator collection as .cias.
Other homebrew related stuff, like VC injections and videos. 7 videos,, the entire Super Mario Advance series, Sonic Advance, Zelda GBA, Pokemon, Kirby GBA, Metroid GBA, Fire Emblem GBA series..es.
For GBC, I have the entire Oracle series, Pokemon, including Green, Tetris, Super Mario Land (including Wario Land)
NES, entire Mario series, Zelda, then Smash classics like Ice Climber, Balloon Fight, ect.
SNES, pretty much all 9 essentials
And I have some homebrew and DS games saved to NAND.
I've cleaned the games I don't play and have no plan to, and still have 200 games.
TAKE THAT!