Every credit card you open is a "new account". It ticks the count reported on your credit report (and per credit karma, credit journey and the like). Using this as an argument seems odd to me, as clearly Citi was awarding miles for opening up a NEW credit card account with them and spending the MSR amount.

I have a poorly scanned image of a mailer. It says nothing that would cause anyone to consider having a problem using it. I wish I had a copy of the T&C's from that time. Checking ... I do have saved PDFs of many of our apps, but no legalese ... just the finished app where we had changed dozens of fields to apply correctly.