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Covert communication is achieved when a transmitter Alice can successfully transmit a message to a receiver Bob without being detected by an attentive and capable adversary Willie. Early results demonstrated the difficulty of the covert communications problem: with AWGN discrete-time channels between all parties, only O(sqrt(n)) bits can be sent in n channel uses. But it was soon recognized that uncertainty about the environment at Willie, for example, uncertainty in his own noise statistics, could allow for a positive rate: O(n) bits can be sent covertly in n channel uses. However, most covert communication results, including this promising positive rate result, have been obtained for a discrete-time communications channel. Here, we demonstrate that the assumption of a discrete-time channel is problematic when trying to exploit Willie's noise uncertainty. In particular, we demonstrate that if Alice transmits ω(sqrt(T)) bits in a length T interval to Bob on a continuous-time channel, then there exists a detector at Willie that can detect her transmission, as the probability of false alarm and missed detection PMD+PFA→0 as T→∞. In other words, the communication is not covert, unlike the case of a discrete-time channel.