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There's a sort of smart alecky response justified by the literal wording of the rule, and that is that a "no play" is not an act, but the lack of one.
There was a discussion a couple mos. ago or so about this wording in the Rules section of Coach Huey's Web board. There are just certain things customarily allowed and others customarily disallowed.
Ever since the neutral zone came into the game, and actually even to an extent beforehand (when offside/onside was determined by foot position), the offense has wanted to maximize its advantage in control of when the ball is snapped. Ultimately it can be said that the aim of all attempts to draw the other team offside is not to get a encroachment penalties but to make team B react more slowly and to negate certain "tells" team A might have as to when the snap is coming. (The recently discussed case of the player who vaulted the snapper to block a try kick obviously resulted from A's failure to disguise the snap's timing.) However, in any particular case that might result in encroachment by B, and in some situations team A is definitely trying to draw it.
Rules makers in all the football governing bodies have decided that certain specific pre-snap fakes by A will be ruled as false starts either because they decided such tactics gave A too much of an advantage disguising their tells, or that it was too easy to draw B offside on any particular down by such moves. Probably with each such prohibition, however, teams adjusted to a new equilibrium in terms of how quickly B can react, and the proportion of plays prevented or negated by penalty resumed its previous percentages.
However, to some degree the general false start rules were left open to judgement in all codes, and Fed's language above is the most open ended of all. Everybody knows that extreme variation in the loudness of the snap count ("...hut...hut...HUT") is exactly an act (a fake "tell") intended to cause B to encroach, but has anybody ever flagged it? The same could be said of a snap count used with "no play", for if there's no intention to snap the ball, why use a snap count? (That's the comeback to the smart aleck answer above -- failure to snap the ball isn't an act, but verbal signals are.)
However, it is conceivable that "hut...HUT" is used to disguise an involuntary tell that some signal callers might have where they give the final "hut" a little more loudness without realizing it. Similarly, "no play" is used as a tool against defenses, paticularly blitzing ones, that have been getting into the offensive backfield too quickly. So custom is to allow these to preserve the officials' sense of how much surprise team A is entitled to inflict by the timing of their snap.
Robert
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