Any bad syntax error will do it, like leaving out a quote here or there... I'm making one up quick, I'll post the SVG part when I'm done. Should only take a few minutes to whip up.
Basically you need to get this error from theme builder:
Warning: The following resources could not be included in the theme for reasons explained below:
homescreen.svg: Failed to compile SVG file.
Errors in homescreen.svg:
Error: The element <animate> named "_anim_4" has a reference to "NoHome_Img_Normal49" which is not found.
1 error(s) were encountered.
Just got done building it, I'll post it up quick...