It probably refersmight refer to having multiple possible decryption states. Basically, you start with an extra-large blob of encrypted data, and multiple keys. Each key results in a different document.
Obviously, the encrypted data needs to be large enough to hold all documents, but there's no way to prove how many keys exist. Make it large enough to hold 10 documents, for example, and you could have 2 false keys, one real key, and a bunch of random data.