When you have sex in your dream and actually get off. I cant speak for women but this totally counts for dudes. If it was real and felt real and you remember it then the only difference between that and real sex is the chance of getting the chick prego or catching a disease. As well, lets face it, at least for a dream score you actually remember having sex, maybe its even more real then all those drunken binges.
Dream Scores are awesome and count and the greatest part about it is you dont actually have to count it toward your actual number if you dont want to, booya.