Some vg developers like to use that title. It's usually the "big bosses" that are already well known in the game industry.
examples: Hideo Kojima and David Cage (heavy rain, fahrenheit)
These two have their own game companies, they have "complete" control over their games... So I'd say it takes a lot of leadership skills (like a producer), a lot of creativity (game design / story) and recognition (or money).
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