Perhaps a poorly chosen phrase. The earlier head designs had an open oil gallery sealed by the head gasket that tended to fail and leak large amounts of oil into the #1 cylinder. The 3.5L was more likely to leak than the 3.0L due to the larger bore.

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Current stable:
1995 E320 157K (Nancy)
1983 500SL 125K (SLoL)

Gone but not forgotten:
1986 300SDL (RIP)
1991 350SD
1991 560SEL
1990 560SEL
1986 500SEL Euro (Rusted to nothing at 47K!)

Gone and wanting to forget:
1985 524TD 167K (TotalDumpster™) [Definitely NOT a Benz]