[android-developers] null is the loneliest number

I'm looking at this function in Activity:

public Window getWindow ()

Since: API Level 1

Retrieve the current Window for the activity. This can be used to directly access parts of the Window API that are not available through Activity/Screen.

Returns

Window The current window, or null if the activity is not visual.

It says it returns "null if the activity is not visual".

In layman's terms, when does it return null?  What constitutes a "not visual" activity?

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