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If they can figure out what a <title> tag looks like, don't you think they could figure out what a comment looks like?
In addition to the size issue, you run an additional risk. If someone does a hand check of your site, that would be a mark of someone who is trying to spam. They will look much deeper for any real infractions.
I suspect their top results are due to the fact that they have spent a lot of time generating links and has nothing to do with the comments tags.
What is obvious is that Google does not penalise for it...
WPG's free advice booklet on optimisation indicates that you should stuff the comment tag with a list of keywords. Does Google read comment tags and is it spamming or is it OK?
I helped right that stuff (and many others) the reference is pre-year 2000 -- someone there still believes it's valid - it is not.
Please don't hold this against me - was younger then and much more foolish. ;)