The validity of a recent estimate of an upper limit of charm production in
central Pb + Pb collisions at 158 A GeV is critically discussed. Within a s
imple model we study properties of the background subtraction procedure use
d for an extraction of the charm signal from the analysis of dilepton spect
ra. We demonstrate that a production asymmetry between positively and negat
ively charged background muons and a large multiplicity of signal pairs can
lead to biased results. Therefore, the applicability of this procedure for
the analysis of nucleus-nucleus data should be reconsidered before final c
onclusions on the upper limit estimate of charm production can be drawn.