Oh. Not really. We'll make it nice and complicated. Of course silly.. You can't just paste it right into the web page. You have to make a PDF or something else and add it as an attachment.
--
Here is my useless addition.
--
"The most persuasive comments will be comments that provide specific facts about how measures that protect access to works harm, or are likely to harm, noninfringing uses by users of copyrighted works."
In other words.. Guilty until proven innocent.
Also. How about have a non-lawyer write up these public comments? The average US reading grade level is very low. It would be best to accept comments from the "public" at the reading level of the "public."