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The phrase "we have no comment" is correct and usable in written English
You can use this phrase when you would like to decline to comment on a particular matter. For example, a spokesperson for a company might say "We have no comment at this time regarding the allegations."
Exact(58)
We have no comment".
But we have no comment on them".
We have no comment to make".
We have no comment on this".
Due to litigation we have no comment at this time.
As such we have no comment to make".
"From our perspective, we have no comment," Mr. Byars said.
We have no comment whatever to make on this.
"We have no comment until we read it".
"It's still under investigation, and we have no comment at this time," the detective said.
We have no comment on the prosecution or how they have chosen to characterize it".
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Since I tried Ludwig back in 2017, I have been constantly using it in both editing and translation. Ever since, I suggest it to my translators at ProSciEditing.

Justyna Jupowicz-Kozak
CEO of Professional Science Editing for Scientists @ prosciediting.com