> There are no items in `[]` so that doesn't seem like a true statement to me.

It's true by [Vacuous_truth](https://en.wikipedia.org/wiki/Vacuous_truth).

> So, at least consistency pulls towards `false`.

You are misunderstanding what `includes` does when there is no argument.

```js
[1].includes(); // false
[void 0].includes(); // true
```

Consistency with `every` pulls towards `true`.
                                          
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