You could always eat all your file descriptors, not quite a one liner, but try running a web server at the same time as this little sucker. This is why clever persons use per process limitations.

#!/usr/bin/perl
for (;;) {
  my $fh; eval {open($fh, "foo.pl")};
  last if $!;
  push @foo, $fh;
}
print "all out $!\n";
sleep(1000);
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