Female led relationships discussion

I recently stumbled upon an idea while browsing another discussion, and it reminded me that people in D/s dynamics use this term quite a bit. However, I keep thinking that as expressions go, it’s somewhat… well… lazy.

It appears to refer to one of two things—or perhaps both:

1. A submissive who is actively manipulating the situation.
2. A submissive who is politely expressing their own wants and needs.

To me, it makes more sense to label #1 as straightforward manipulation, and #2 simply as good communication. I also came across a blog post discussing this exact issue, arguing that the phrase has become somewhat empty of meaning.

The article is worth reading, along with its comments section. Has “Topping From The Bottom” turned into an overused cliché? Is it just a lazy way of thinking? Or is there deeper significance to be found?