Wenger's so-called "Invincibles" team achieved that feat over 38 league games in 2003-04, but he said that Jose Mourinho's Chelsea, with seven wins and two draws from the opening nine games, still have much to do.
"Chelsea are in a strong position but it would not be realistic to judge them now," he said.
"There are how many games played? There's a long way to go. It's too early."
Arsenal lost 2-0 at Stamford Bridge earlier this month and have won only three of their nine games, leaving them nine points behind the leaders.
But Wenger, speaking ahead of Saturday's home game against bottom club Burnley, said the statistics did not take into account who they had played or the number of away games.
"I do not write ourselves off," he added. "I have a strong belief we will come back and we can just prove that on the pitch."
Arsenal, who play at home to Anderlecht in the Champions League on Tuesday, have also had a number of injury problems and Wenger confirmed that midfielder Jack Wilshere is likely to miss the Burnley game.
He is suffering from a kick on the knee, but Wenger hopes to have him available against Anderlecht.
The manager said Theo Walcott was coming back to fitness and French striker Olivier Giroud was "three weeks ahead of schedule and I think he will join in normal training after the international break".
(Reporting By Steve Tongue; editing by Toby Davis)
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