That's actually sort of false! WSL was originally designed for Android, to enable Android apps on Windows Mobile phones. (I have a Lumia which has a test build of this from back in the day.)
I'm unsure when the branding decision was made, but the possibility of again involving Android support was probably considered.
I am quite sure this has not much to do with Android, given that this, including the naming scheme, traces back to 1999 with "Windows Services for UNIX".
They should say "for Android apps". Boom. Makes more sense. I'm sure there are other phrasing tweaks that would also work.
But it's just like Microsoft to blindly settle on a name that doesn't make sense, based on advice from legal, and not probe it a bit more, or play with it to make more sense while still fitting the guidelines of legal advice, and to cite the legal guidance as the reason it has to be mediocre and cannot change. (Source: I once worked for MS.)
Edit: to be clear, I'm also reacting to the "windows subsystem for Linux", which they used the same justification for.
Android branding guidelines are very unlikely to matter at this point, given that it's descriptive use (not forbidden by trademark law in the first place) anyways...
I don't think that's what descriptive fair use means.
> Descriptive Fair Use: Found at 15 U.S.C. § 1115(b)(4), the descriptive fair use defense protects your ability to use ordinary words to describe your own goods or services, even if those words happen to be part of someone's trademark.
Since the Windows Subsystem for Android actually runs Android, "Windows Subsystem for Android" is a product name and not just a description, and "Android" isn't a generic descriptive term in this context, it seems to me that Microsoft is using Google's Android trademark in a way that isn't protected as fair use.
Right, I should have said "nominative" rather than "descriptive", at least as far as US law is concerned. It's directly below "descriptive" in your link.
Really I wasn't trying to name the exact defence but gesture at the principal that trade marks prevent competitors from using names that might confuse customers, but they don't prevent competitors (or anyone else) from talking about the product. It was just a coincidence that I used a word that happened to also be the name of a specific kind of fair use.