Michael Bay has made it clear in comments made in the special features for Transformers: Revenge of the Fallen and in various media interviews that he held much disdain for Terminator Salvation's McG for his use of suspiciously Transformer like robots in his film. As a sign of that, here is an image captured by IloveMcG that illustrates a dig at the film by apparently labeling one of the cannon fodder Decepticons in the desert battle with "T1000", the classic name for the original Terminator model.
Update: As pointed out in the comments I had my Terminator models confused. The T-1000 is the classic villain Terminator played by Robert Patrick in Terminator 2: Judgement Day. The T-800 is the Arnold Schwarzenegger's role as the villain in Terminator 1 and hero for T2. For Terminator 3, he was the "'850 series Model 101', a 'T-850', and a 'T-101'". Long story short, T-1000 is appropriate name for a Decepticon when taking a dig at the Terminator franchise since both are bad guys.