Not really. I believe : is the "true" builtin. So it's like running a program that exits with zero and writes nothing to stdout. The >> streams the empty stdout into the named file.
I'm betting that's why none ever materialized. Most tools that can manipulate a file, can also create that file first, so there's just never been a usecase.
Right-clicking the desktop to create a new txt file in Windows feels so natural, but I can't really think of any time you'd want to create a new file and do nothing with it in a CLI.
One use case is if you're running a web server that is configured to return a "maintenance" page instead of the live site if a particular file exists. Which is actually pretty cool because then you don't have to update the config when you need to do something or let your users get a bunch of 502 errors, you just touch maintenance and you're good.