The ability of your bought marketing efforts to gain free editorial coverage and/or extended online life is lauded as a way of increasing one's marketing ROI. Consequently, in tough economic times, it has become a goal and justification in and of itself with agencies reporting that clients ask them to "make us a viral" while clients are regaled with case studies like Cadbury's
gorilla.
Earned media is more valuable than bought media only if it is earned for the right reasons. If it's just picked up by media outlets desperate to fill their 24 hour schedule or is passed around for its creativity or shock value rather than the underlying purpose, then is that coverage really worth earning?