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It's a measure of how "chatty" the "conversation" is on that stream.
If the Follow TCP Stream window is showing client and server, it is the number of times the text color changes.
(That's not very scientific and not how the code calculates the count but pretty easy to visualize)

Here are two examples from the Wiki Sample Catures:

http.cap - A simple HTTP request and response

telnet-cooked.pcap (libpcap) - A telnet session in "cooked" (per-line) mode