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This is a usability issue that misleads users where the label is. An extra click will get in the edit mode without anything being visually displayed in the Unnamed label except for a tooltip, but user can type in it. It's not like if there's already a user entered label.
Now that the label has a border when it is selected, this is no longer an issue. When the users goes into edit mode and the label is unnamed the label will be blank with a border around the label and the cursor blinking. See the attachment. If the label is not unnamed the text will be selected.
Created attachment 58166 [details] Editing An Unnamed Label
verified in the latest build 20080311.