An example would be the feud between Booker T and The Rock before Summerslam 2001, now it made sense for Booker to be referred to as a 5 time WCW Champion as he came from the original WCW which went out of business when he came to the WWF/E. The Rock took the title from him at Summerslam but he's a WWF/E wrestler, he was never a WCW guy. Chris Jericho was even though he already left the original WCW two years before that, the one he took from The Rock was also won during the Invasion angle despite the fact that he was also a WWF/E wrestler at that time. Since that version of WCW was part of a WWE storyline, it shouldn't count.