We had this question answered in our recent Kirby Mass Attack dev interview, but just incase you missed it, here's another answer that IGN was given.
As you know, this is a game in which players are able to directly touch the stage in the lower screen. Of course, that type of control would also be possible on the 3DS, but the game would not end up taking advantage of the three-dimensionality of the upper 3DS screen, which is a defining characteristic of the 3DS hardware. So if we made this game for the 3DS, I think we would be asked, "Why did you make this game for the 3DS?"I think that given the characteristics of Kirby Mass Attack, it's only natural that it was developed for the DS. - Mari Shirakawa
Full interview here
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