Cut him some slack...Toppy's had 23 whole women in his lifetime, which works out to something like .0000000004% of the population.
With all that "experience" going for him...he's qualified to decide for everyone else what is and isn't "fat".
Then there is the rule of three...
Stifler: You're a disgrace to men everywhere. I mean, look at the Stif-meister. I got laid 23 times this year, and I'm not counting the hummer I got in the library stacks, baby!
Oz: Here's a new idea for you, Stifler. You find a girl, you two become best friends and you don't bother counting how many times you have sex with each other: you just laugh at the people who do count.
Stifler: Here's a new idea for you: I'll get you a spoon so you can eat my ass.
Jessica: If a guy tells you how many girls he's hooked up with, it's not even close to that. You take that number and divide it by three, then you get the real total. OK, so if Kevin is saying it's been three girls it's more like one or none.
Vicky: None?
Jessica: The rule of three. It's an exact science. Consistent as gravity.