If you read through the email chain you'll see that it occurred before the docket even was made public to be commented on: "The docket will be on internet priva

If you read through the email chain you'll see that it occurred before the docket even was made public to be commented on: "The docket will be on internet privacy, it is not yet published. We believe it will be published later this month"; if they already had prewritten comments ready at that time, that confirms fraud by CQ, because the public can't write comments on something that doesn't yet exist. Meanwhile CQ is repeatedly insistent that the submissions be recorded individually, and not by the bulk csv method; and when the API limits turn out to be too strict they go to great effort to do it anyway: "We will need to set up multiple servers to feed the API simultaneously to meet the delivery needs of our clients" -- 114 api keys compared to one or two for most other groups. None of which sits well with your idea that they'd intentionally sort them first. Bulk submissions might be expected to be sorted. The assumption for individually submitted comments is that they're individually submitted; it exposes the astroturfiness very clearly when all the identical comments show up in strict order in the docket. (Or at the very least, if this was just a dumb goofup or excessive tidiness, why wouldn't they have simply explained that as the obvious excuse the moment it started being reported? There'd be plenty of supporting evidence, the stage space alone would have had to have been significant)