It's a good point. I'm not sure how it would be tracked. I just can't think of anyone I know that even might browse with JS off. It's on as a default setting and I think it is fair to say that most of the world don't know what JS is.
Hi new internet friend.
I have it whitelisted for some (perhaps many) sites. But even if it was on, things like google analytics are still blocked (at least I hope they are! Tracking is a never-ending battle)