I first heard it used to traditionally describe computer security whizzes like Kevin Mitnick, Diffie & Hellman, Robert Morris (Morris worm) etc. But apparently the last ~15 years it's just a compliment for the next random corporate grifter who has 0 technical experience and is just in for the $$$.
However Gates definitely deserves the title, he had helped make some significant contributions a few years before or right after dropping out of Harvard by co-authoring a paper in complexity theory next to a very prominent name in the field.
https://www.npr.org/templates/story/story.php?storyId=922367...