Well, it isnt entirely impossible, since nothing on an online game (Especially by TQ) is impossible.
The server can obviously spawn items, with something most likely simialr to, but not limited to, the following:
Code:
new gSpawnedItems[MAX_ITEMS];
public OnItemSpawn(itemid)
{
gSpawnedItems[MAX_ITEMS]++;
return 1;
}
Bad example, mainly because there is no other code to support this, so it wouldnt work in any way, but i will try to explain what i mean:
The server spawns items, and obviously it has to add an ID to each item, in order to keep track of it. In this code, it is assumed that it adds 1 to the highest item ID, which may not be the case for CO, but that doesnt matter right now:P
But, of course, that would lead to an extremely high number for item IDs, 999996786 for example.
Items also dissapear, so a code similar to this:
Code:
public OnItemDelete(itemid)
{
gSpawnedItems[MAX_ITEMS]--;
}
Would be there, so, if 40 items spawned, the [MAX_ITEMS] would equal [40], if 5 were left on the floor long enought to vanish, or were sold, [MAX_ITEMS] would have 5 subtracted from it, [35].
But, from what i know about CO (Which is little, and im proud of it:P), you would have to send TQ code in order to test this, and good luck with that:P
Code:
"tbb\b\b\bC_\b+_\b+FTW";
Stick that code in ur pipe and smoke it

EDIT:
By "Equal 40", i mean as an array, not actually equaling 40.