Why isn't otto graham ever considered to be one of the best quarterbacks of all time?

Most educated people consider him to be no lower than 7 or 8 on the all-time list. The people who don't recognized or care about the history of the game don't really matter. The only argument that I have against Graham is that 4 of his 7 victories came in the AAFC. Sure he ended up winning 3 in the NFL, but that's sort of like a team now winning 4 straight UFL victories and then coming to the NFL and winning the SB a few times. Do we really count those UFL victories?