Doesn't matter where it was played -- I think that the game was too short.
That said, I think that a material advantage of three or more points (to the detriment of the resigner of course) or a game that ends in checkmate (fools mate in all likelyhood) should count even if it is under the minimum move threshold to be rated.
I played a guy last night and took his queen on my 3rd move(he had made 2 moves) and he resigned but I didn't get any points. I assume it was too short a game? Dammit I need those points. Thanks.