|Destroy Kong without being hit!|
First you must unlock the Virtua Squad level in Superstars mode. Then you have to make it to the 7th mini-game, which is the fight against Kong. He is really quite simple to defeat, all you have to do to defeat him is alternate between him and the guys below. So shoot one guy below, then shoot Kong. Rinse and repeat until he is dead. Make sure not to get hit to unlock the achievement.
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