one can imagine one specific type of universe that might spontaneously appear and need not disappear almost immediately thereafter because of the constraints of the Uncertainty Principle and energy conservation. Namely, a compact universe with zero total energy. Now, I would like nothing better than to suggest that this is precisely the universe we live in. This would be the easy way out, but I am more interested here in being true to our current understanding of the universe than in making an apparently easy and convincing case for creating it from nothing.