I'm going to say no for the reason in bold below.
Recently Courtney Baird wrote this article touting obstacle races. I have never done one but I can imagine climbing 12 foot walls, climbing a quarter-pipe, doing the monkey bars and jumping into freezing water would be difficult. However, you need to read the FAQ on Tough Mudder's website: "it's fine by us if you want to skip an obstacle..." So, you could easily skip every obstacle, walk 10-12 miles, get a headband and say you finished. Not very tough. It's the same argument as finishing an IM in 10 hours vs. 16:59.
You're also allowed to help each other, don't have to deal with a mass swim start, deal with running after biking and don't seem to have a time limit.
It might be hard if you complete every obstacle but since you're not required to complete them all, it's not actually that hard.
How many people passed out at a 3 mile Warrior Dash last year?
Now, the Worlds Toughest Mudder...that is probably more difficult...assuming you do at least 2 laps.