This factory function implements closure for private state: 1) The count variable is enclosed in the factory function's scope, 2) It's not directly accessible from outside the returned object, 3) It can only be accessed or modified through the provided methods, 4) Each created counter has its own independent count variable, 5) This achieves true encapsulation without using classes or symbols, 6) This pattern is often used for creating objects with private state in JavaScript.