We are all familiar with the question: "If a tree falls in a forest without anyone nearby to hear it, does it make a sound?" Lawyers may restate the question as one of Article III standing, or as the Supreme Court said this June in TransUnion LLC v. Ramirez, 141 S. Ct. 2190, "A letter that is not sent does not harm anyone," and therefore does not give a basis to sue for a statutory wrong, "no matter how insulting the letter is."