1200 cal daily minimum or net minimum?

No scientific evidence here, but I thought it was also interesting that Slim-Fast also uses the same 1200 calorie recommendation, but doesn't encourage you to eat back any exercise.
The Slim-Fast 3-2-1 plan which is not designed to be a "forever" plan, is as follows:

1 500 calorie, balanced meal per day (500 cals)
2 meal bars or shakes per day (2 x 200 cals)
3 100 calorie snacks per day (3 x 100 cals)

Total Calories: 1200

Also, the medically backed Optifast program (http://optifast.com) which has a plethora of scientific research and development behind it requires that you successfully lose at least a pound using a 1200 calorie diet before starting supplements. When you are rolling off supplements, you are put on a 1200 calorie diet as well.

I actually find many days, that 1200 calories seems like a lot to eat if you are restricting sugar, fried foods, fatty foods, etc.
It's quite easy to have a ~200 calorie breakfast/lunch, and 100 calorie snacks followed by a 500 calorie dinner.

I have learned to cook healthy, and the meals come out at about these numbers.

Just my two cents for what it's worth (probably about a cent and a half!)