Yeah, "hybrid" is one of those terms that means different things to different people. - By definition it's simply "re-built in a non-standard configuration", which can be anything from different thrust bearings, but otherwise standard, to the turbine from a 3076 matches with the compressor of a 2854 (because I'm pretty sure you can't buy a 3054 off the shelf).
As far as I'm concerned, just putting the thrust bearing in really doesn't count... especially if it's because they bought a kit off eBay and rebuilt it themselves without rebalancing etc.
As an example; TurboTechnics will build you a hybrid turbo (although I'm pretty sure they recommend a standard configuration unless you're chasing particular characteristics), but they'll also put a 360 degree thrust bearing in. - It's the fact that they've assembled a custom turbo for you that makes it a hybrid rather than whacking the thrust bearing on the end... which may really be because the original parts won't fit a custom unit.