False positives with calling count() inside loop

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The loop performance error MEQP1.Performance.Loop.ArraySize should not trigger when the variable that count() is being called on is declared inside that same loop. For example:

foreach ($productIds as $productId) {
    $images = getImages($productId);
    echo count($images) . "\n";
}

In this case, it isn't possible to call count() outside the loop, and therefore the warning is invalid.