  We examine the tidal disruption event scenario to explain Sw 1644+57, a
powerful and persistent X-ray source which suddenly became active as GRB
110328A. The precise localization at the center of a z=0.35 galaxy argues for
activity of the central engine as the underlying cause. We look at the
suggestion by Bloom et al of the possibility of a tidal disruption event (TDE).
We argue that Sw 1644+57 cannot be explained by the traditional TDE model in
which the periastron distance is close to the tidal disruption radius - three
independent lines of argument indicate the orbit must be deeply plunging or
else the powerful jet we are observing could not be produced. These arguments
stem from (i) comparing the early X-ray light curve to the expected theoretical
fallback rate, (ii) looking at the time of transition to disk-dominated decay,
and (iii) considering the TDE rate. Due to the extreme excess in the tidal
force above that which would be required minimally to disrupt the star in a
deeply plunging orbit at periastron, we suggest this scenario might be referred
to more descriptively as a TOE (tidal obliteration event) rather than a TDE.
