To me the hardest record to beat is highest TPE reached in a career. When Toe got the record at about 2270 TPE, he had a few advantages that future players will not. The post game show system that is in place for first year players was available to everyone for 5 seasons, so that alone is an extra 60 TPE. On top of that seasons used to take longer and off-seasons too, finally play by plays used to be available for all games 5-7 in the playoffs, not just the finals. When you combine all those factors I don't think it's going to be possible for someone to surpass the record. Unless some sort of TPE inflation happens its really a record that can't be broken even by the most hard-core TPE earners on the site and that's probably a good thing since TPE is already inflated enough.