Nope. That's a rule of thumb for individual fighters (with separate APs) outnumbering an opponent, and is meant to restrict the possible multiple opponent penalty to around -15 (if the penalty is still -3 per extra opp these days).
Since the defender doesn't get any penalties for fighting multiple opponents when fighting a horde with a collective rating it stands to reason that that rule is not in effect.
One Horde counts as one opponent.
When i'm already talking about Hordes i'd like to add something about calculating collective ratings. By the general rules a swarm of, say, rats would have little chance of scaring a player hero, since by taking a single rat's rating and adding zillions of APs you don't end up with a scary swarm of nasty rats but with a tedious time consumer.
This assumes that the swarm is meant to be a _threat_ to the player heroes (otherwise what's the point of having a contest in the first place?). Hence, give the Horde a rating that can actually contest somewhat against the player heroes' ratings (at least within 20 points of the heroes' applicable ability ratings), and add enough APs to make them fearsome. Otherwise it's just a waste of session time.
-- - Mikael Raaterova [.sig omitted on legal advice]
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