I've updated the OP with some more details.
Of particular interest is their statement of sales requirements. 20k sales amounts to $200,000-300,000 of revenue, of which Nintendo gets to keep 30%. That suggests a dev cost between $140,000 and $210,000.
If 20k is a typical break-even point for WiiWare, then even lesser-known titles like Tiki Towers and Sandy Beach should be modestly successful from NA sales alone, if Channel Surfing estimates are accurate.

"The worst part about these reviews is they are [subjective]--and their scores often depend on how drunk you got the media at a Street Fighter event." — Mona Hamilton, Capcom Senior VP of Marketing
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