It depends on what you consider a mini-game, I suppose. I don't like them because I can't remember one that didn't seem like a needless cop-out, unless the entire game is structured around them (Wario, Shenmue).
Was the driving level in Gears of War a minigame? I say yes, because it was something superfluous to the flow of the rest of the game. It was used only to break up the action (annoyingly, imo), and could have been omitted without the main game suffering.
Riding inside the cart in the mines, though, was not a mini-game.
Shooting free throws in NBA 2k = not a mini-game, as it's an integral part of the whole.
The hand-to-hand combat in COD3 = mini-game.
Hacking in Splinter Cell, the Halo warthog = not mini-games.
Gambling in Jade Empire = mini-game.
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