I’m guessing he’s more referring to the television show with Nicole Ritchie where they both acted shamelessly stupid for the attention.

I supposed it’s possible she’s really as dumb as she portrayed on her “reality” tv show, but I find it extremely unlikely given the money and education.

You know, that's fair, I completely forgot that show even existed. I guess I sort of categorize it as "a tv show" and thus fictional.