When I worked at Gamestation, around 10 boxes of a new PlayStation title were put out on display, the discs and manuals put in a plastic sleeve and stored.
It was necessary to do this then to obviously have the title on display.
Lots of other Video-game shops adopted the same practice.
I remember my dismay of buying a "New" disc based game from a major retailer, upon seeing the staff member rummage in a drawer, fish out a badly bagged disc and manual, and then roughly shove it onto the spindle in the case.
It was almost always dusty and marked.
This to me does not mean "New" once a neanderthal has manhandled your disc.