I don't see how.
2005: PS3 0, 360 8m
2006: PS3 5m, 360 14m
2007: PS3 14m, 360 20m
2008: PS3 20m, 360 28m (claimed)
That to me looks like a shrinking 360 lead. And it consistent with sales data, where PS3 has matched the 360 in Europe, outsold it by 2m in Japan, and matched it in US.
It's also worth noting the tricks that Microsoft uses in it's sales sale. over 1m of those consoles are store demo units (which they count), and many of them are likely to be replaceements for RROD.
We wil never know how many ACTIVE 360's there are, but I would suggest 23m is a more realistic non-MS viral marketing number.