Well, according to Robin Goldstein, the author of The Wine Trials , nothing more than a lively imagination and payment of $250.00 fee. Robin submitted the menu of a fictitious restaurant sporting a high priced "reserve" wine list made up (depending on who you choose to believe: Goldstein or The Wine Spectator) largely or partially from wines that had been given low-ratings by The Wine Spectator, and received their Award of Excellence.
You can read Robin's side of the story HERE and The Wine Spectator's response to the hoax HERE.
My thanks out to Crazy Raven for tipping me off to this amusing story. -Bob dG