If you don't have it yet, I recommend combining this with "Keep Your Distance" for making 10 3-Pointers in One Game.
Start a Game against your 2nd controller with 1 minute quarters.
For 1st player, we will need to score Ten 3-Pointers during this game
For 2nd player, we need to do 10+ Backcourt Violations (Turnovers)
You will get the Net Gain Achievement at the end of the game