This has to be done against the AI in any mode. Select Play Custom, set the Game Mode to Power Chips, and change the settings to:
AI Difficulty: Novice
Column Drop: No
Drop Clock: Disabled
Score Limit: None
Time Limit: 1:00
I found it easiest to try to get two chips on top of eachother, then wait for the Hand power chip. Once you get the Hand, place it on your two chips and the opponent won't be able to lay a chip there. You can then score a Connect 4, and just let the time run out. If you are about to lose/tie a game, you can just press the start button and select Restart; this won't count as a loss.
For some reason I had to view the Trophy for this specific achievement in the my Trophies collection before it would unlock.