This is how I learned false eyes when I was playing Go. A false eye is an eye where any of its surrounding stones can be placed in atari, and saving them would necessitate completely filling in the eye. This sounds the same as what is discussed on this page, but...

I saw this diagram in seki:

False eye in a seki  

On the page, it states that, under Japanese scoring, this eye would not count as it is false. But how can it be considered a false eye? The marked stone cannot be placed in atari, and thus cannot be captured. That would make it alive, wouldn't it?