In In re Watkins, 279 S.W.3d 633 (Tex. 2009), the Court was presented with the issue of whether the defendant could challenge, by interlocutory appeal and writ of mandamus, the trial court's decision to grant an extension to serve a compliant report. In passing, the Court noted that "the separate writings join issue again today on the question whether the item served was a deficient report or no report at all." Id. at 634. However, resolution of the issue did not matter as "if no report was served, interlocutory appeal was available, so mandamus is unnecessary," and "if the report was merely deficient, then an interlocutory appeal was prohibited, and granting mandamus to review it would subvert the Legislature's limit on such review." Id. In a concurring opinion, Justice Johnson noted that the report served was not a deficient expert report but rather no report at all. Id. at 635-36 (Johnson, J., concurring). "While the document is authored by a physician, it does not show that as of the date of the report the author held any opinion as to (1) applicable standards of care for the treatment in question, (2) the manner in which care rendered by the defendant physician failed to meet the standards, or (3) the causal relationship between that failure and the harm claimed." Id. at 635. Similarly, Justice Willett filed a concurring opinion agreeing with Justice Johnson that the report was not a statutory expert report at all, but noted that once again the Court could not address the issue for procedural reasons. Id. at 638. Justice Willett conceded that this issue was not squarely before the Court, but again discussed the no report versus deficient report issue in his concurrence. In Watkins, the expert report consisted of a one-page narrative of the treatment the patient received. Id. at 638. The trial court determined that the issue was "not even close" and found the report was merely a narrative and did not constitute an expert report, and then granted an extension for the claimant to cure. Id. Justice Willett described the issue as "whether there can be interlocutory review of a denied dismissal motion when there is no report as opposed to (and note this locution) 'a report that implicated a provider's conduct but was somehow deficient.'" Id. at 638. Justice Willett noted that in Watkins, the claimant's report implicated "nobody's conduct" and "'is no more a report than a doctor-signed prescription or Christmas card would be.'" Id. Justice Willett continued: "I concede that courts, this one included, cannot decree with micrometer-like precision when something falls from deficient to so-deficient-it's-absent. Each case has its own distinct facts, but judges are not incapable of applying indistinct lines, or at minimum prescribing the outer ones. One bright-line marker seems beyond reasonable objection: when a "report" contains none of the statutorily prescribed contents. There must exist an agreed outer fringe, and the superficial document in this case lies beyond it." Id. at 639.