Same here. Exclusively for txt files. Especially useful because sometimes you ONLY need a txt file with a title, no content, to act as a crude bit of meta-data for a folder.

The excuse given in the article however just seems like rewarding bad behavior, and explains at least one reason why the Windows GUI is such a disaster (at this point, it's just years and years of junk accumulation as well, but even in 95 there always seemed to be at least 3 ways of doing the same thing).