How to treat this sentence of Japanese mahjong? What is a draw?

Although your cards are empty draws, you still draw.

But if you don't touch your three 20,000 cards and they are all in your hand (that is, 222,245,600 in your hand), it is not a draw (according to the rules of the weather, it is not a draw, and the rules are different in different places). In other words, it can't be counted as a 20,000-ride lottery, nor can it be counted as a 22-22 touch lottery.