[dragonwriter]

> Does the number of comments really change anything?

My understanding of regulatory proceedings is that the number and substance of the comments tends to play a role but (in a way, somewhat opposite of many legislative proceedings) the substance is a lot more significant than the numbers. The purpose of the comment period isn't to get a pulse of popular opinion, its to assure that the policy analysis underlying the regulatory action is able to consider all relevant information, including information that may not have been apparent to the commission's staff.

The individually most effective comments, then, are probably those like Mozilla's, which not only makes very specific recommendations, directly addressing the points raised in the call for comments, with strong support and analysis behind the recommendations.