I think they have to give it, at least, an honorable mention. The game was too big for them to get into the goty and say "well, nothing of note was released"...
I have no problem with them making a "Best unfinished game" to accommodate it, or it competing with the other games. In fact, given the amount of play and how beloved it is, I think it has a decent shot at being goty.
We should consider that the categories are not hard set, written in stone, inmutable thing. They had a "Best Overwatch character" category last year, and it was more contended than some others.
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