It seems to imply a concerted effort to mention the title of the movie in the script in a meta, fourth wall breaking sort of way.
In some cases that's obviously true - Hot Tub Time Machine, Suicide Squad from their examples - but other times an untitled script just needs a title and it's plucked from the script.
I think there's a distinction there, because the latter is less of an Easter Egg sort of thing and more "ok now we need a title."