I don't see anywhere in the T&C's where they 'require' you to get points for the stay, as opposed to miles. Could you get miles and then, as per the terms, have enough points added to your earned points (which would be zero) to reach 16,000 (which means they would have to add 16,000 points)?
Or am I missing it in the terms somewhere? They seem to imply that you need to earn points, since they use the phrase "points earned", but never come out and say it and zero is a number of points earned.
Anyone remember previous promotions if they specifically required you to earn points instead of miles to participate?