* Many of his films were Westerns: In Westerns, death was often a common occurrence, and it's hard to track every character killed in every film.
* The term "killed" is ambiguous: Does this mean he was shot, stabbed, or died of other causes? There are many ways to die in a film.
* "Killed" might not be the right term: In some films, he might have disappeared or been presumed dead, but his fate wasn't explicitly shown.
While a definitive answer doesn't exist, you could find some information by:
* Consulting film databases: Sites like IMDb offer details on character deaths in films.
* Reading about his career: Biographies and articles about John Wayne might discuss his death scenes in specific films.
However, even with these resources, getting a complete and accurate count would be extremely difficult.