Any tech-savvy thief will have difficulty getting through a steering lock which will make a noise when tampered with.

Source: https://www.express.co.uk/life-style/cars/1828529/land-rover-theft-car-crime

Conventional wisdom suggests that Trump and DeSantis may bludgeon each other significantly enough to open a new lane that won’t be filled by any of the milquetoast Haley-Pompeo-Pence also-rans, who are barely able to make a noise amid the clatter.”

Source: https://politicalwire.com/2023/02/16/some-republicans-may-try-a-late-entry-in-2024-primary/

Even if the phone is on silent, advocates warn your phone may still make a noise, vibrate or read out the alert.

Source: https://augustafreepress.com/news/this-is-only-a-test-phones-radio-tv-to-receive-message-wednesday/

“If a tree falls in the forest and no one is around to hear it, does it make a noise?”

Source: https://www.etftrends.com/etf-strategist-channel/what-company-reports-no-investor-around-hear/

The victim heard her five-year-old make a noise so went upstairs to check on her, but around a minute later, the defendant came into the bedroom and spoke to the children.

Source: https://www.liverpoolecho.co.uk/news/liverpool-news/man-held-ex-partner-hostage-26797621