I just went to Amazon, clicked on top Electronics sellers (http://www.amazon.com/gp/bestsellers/electronics/ref=sv_etk_ce_av__1/104-1309862-5032737), and the first Zune I see is at 24, with 7 different iPod models above it.

Perhaps MS did some kind of Dianetics-esque fake buying to get on the list temporarily and then had one of their friendly journos do a piece on it.