Well I suppose he might mean if the character is said or heavily implied to have had breast implants? If I am not mistaken Emma Frost from X-Men has had plastic surgery and some comments by her and her prodigious rack heavily suggest a breast enhancement was among her procedures. Stuff like that. Basically the difference between fake-fake and rea-fake would be that in the former the story tells us the character has fake tits, in the latter they don't.
Of course, aesthetically, there's no real difference. Most artists don't draw tits that well to begin with, really, and they can tend to look fake. Take Rangiku Matsumoto from bleach, for example. I swear the artist just traced some quarters to draw her tits.