"Can you tell a lie if you never open your mouth?" [HOW to BE a MILLIONAIRE]

In How to Be a Millionaire, Farley Joshua needs to find a financial backer so that he can purchase a one-third share in a copper mine. He wants to approach wealthy hotel owner, Willoughby Matthews, with the venture. Farley thinks that there is a chance Mr. Matthews won't go for it on just his word and a mining report. He needs a feather in his cap.

Farley's sister, Penny, proposes, "What if ... what if we can find someone who looks important to go with you?  What if Matthews only thinks the man is rich and backing the mine?"

Farley answers, "That's dishonest."

And she counters, "Can you tell a lie if you never open your mouth?"

Shortly thereafter, Penny comes up with a plan to train a waiter to act like a millionaire to help refer Farley for loan approval.  Because the waiter won't actually say anything (he'll just look impressive) and the mine is a good investment, Penny believes that this presentation is not really lying. 

So I ask you, dear reader, what do you think? "Can you tell a lie if you never open your mouth?"