Well, not *strictly* earned... I understand that credit card MQM bonus also counts toward MM status. In theory (if the program doesn't change, of course), someone could start out with a new Reserve card today, spend $120k per year on it, earning 15k MQM bonus x4 for 60k per year - and become a million miler without ever stepping on a plane in just over 16.5 years.

It's a stupid thing to do, but I would be that Delta and American Express would be very appreciative if you did it!