NHL 2K10

Play 100 games, simple enough though I think these must be done on rookie or pro difficulty. I played a whole slew of games on custom difficulty, yet after I thought I played 100 games, but I ended up having to play another 60 on rookie difficulty before it pops.

My best advice since you can't view any stat pages to see how much you played, is to keep track of it yourself so you have an idea of when to expect it.