Interestingly, this is the second useful empty program I have seen. The other is /bin/true, as discussed at http://trillian.mit.edu/~jc/humor/ATT_Copyright_true.html . That file is not quite empty, due to trying to comment and copyright an empty file!
I remember that two bugs were filed in Debian for this implementation of /bin/true (one for the slow execution and one for the memory use IIRC) but I cannot find them.