The point of the canary, is to turn any non-answer into a practical, or at least a tentative, "yes". If you no longer see an explicit "no", it means "yes".
The difference between a canary and a "no comment" is that "no comment" is an extremely common thing to say whether an allegation is true or not so it's not very suspicious, while stopping a canary is very suspicious.
So it's like the scenario you outlined earlier, but more effective.
No, it isn't. It's pretending that "no comment" means something it doesn't. Just because you want it to mean "yes" doesn't mean it means that. It means "we are not going to comment on this, because we have a sane legal department and we're not going to give you any information one way or another".
If you think "no comment" means either yes or no, you're pretending to know something you don't, and you should absolutely stop and go "wait, why am I lying to myself? And why am I believing my own lie?"
Yes, I was the one saying that _people_ consider it suspicious, but I'm also the one saying that as a company your only course of action is to not comment on legal matters unless legally compelled to. Those two things are not mutually exclusive. People (in aggregate) don't act rationally, so even if it's going to lose you some customers, no comment.