Thanks for the info ~
just as an afterthought.. you could possibly compare data in GA.. to data captured by your server traffic logs.
It wouldnt be perfect as you would have to determine from the site server logs what traffic is human as compared to non human that isnt using a js enabled browser amongst other factors too.
Thanks for the confirmation. Smart thinking about the comparison to logs. I'm not sure that will work in my situation, but it's definitely an alternative. One other thing that comes to mind is adding a <noscript> tag that triggers something to help quantify visitors without JS. It could be something simple like a small and specific <img> that is pulled into the page that can be tracked for number of hits on the img. I'm sure there's a better approach though... but I may explore the <noscript> route to see what I can come up with. Thanks for the feedback.