Personally I lean toward Joe's side with this one, but I do want to point out that it is entirely possible for an unreleased game to have proper packaging and the like. If someone were to come forward with a very authentic-appearing copy of Propellar Arena for the Dreamcast - hell, if we could somehow confirm it was authentically manufactured - would it go in the released section? It's entirely possible that the game was manufactured and then destroyed, or met some similar fate. Another example would be the variant version of Wally Bear on the NES that I owned at one point. Entirely different publisher than the one we're aware of, complete with a glossy professional label, but probably not released at retail.

Just throwing some fuel into the fire, it's an interesting debate.