A nominative use of a trademark is one where the trademark is being used by a non-trademark holder, not to imply any endorsement or sponsorship of a person, product, or service by the trademark holder, nor to misleadingly pass off their product as one belonging to the trademark holder, but rather simply to refer to something in the post convenient way. In explaining why Playboy can not prevent nominative uses of their trademarks, Circuit Judge Nelson quoted (link is to a .pdf) the District court judge (Robert J. Bryan?) as providing the following example of the alternatives open to Terri Welles to describing herself as the 1981 Playmate of the Year:
[T]here is no other way that Ms. Welles can identify or describe herself and her services without venturing into absurd descriptive phrases. To describe herself as the "nude model selected by Mr. Hefner's magazine as its number-one prototypical woman for the year 1981" would be impractical as well as ineffectual in identifying Terri Welles to the public.