I just put 35s on my 2011 JKU with no lift and had no problems whatsoever.
Then I took a couple guys to lunch the next day and rubbed at any decent sized bump. Trimmed the fenders & bent over the pinch seam last night and I'm waiting to play lunchwagon again to see if anything still rubs. I won't do any serious off-roading until I get a lift, 1" min Budget Boost but likely a 2.5" Old Man Emu or Teraflex.
Before trimmed fenders, to quote the wife: "squashy"
2011 Nat Green Rubicon Unlimited, RR XHD Front & Rear, Warn M8000, Rock Hard 4x4 Rails, Flipped Mirror, Cobra 75 CB, MyGIG & Infinity, NAV, Homemade Bikini Top, 35x12.5x17 Toyo MTs on ATX Crawls w/ 0" offset (4.5" B.S.) with trimmed fenders, small lift needed soon.