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What causes a 400 Bad Request error for null (“”) and why would our nginx logs have so many?

Daily logs from Logwatch regularly report 400 Bad Request, null: 1744 Time(s) from our nginx logs. The log entries look like: 123.123.123.123 - - [25/Jan/2011:14:44:19 -0500] "-" 400 173 "-" "-" ...