The website you've linked is nothing more than the "suggestion box" of a leviathan. They don't read the comments. When they're absolutely legally required to do

The website you've linked is nothing more than the "suggestion box" of a leviathan. They don't read the comments. When they're absolutely legally required to do so, they figure out their arguments first, based on politics and the possibility that a Court will or will not overturn their regulations, then they'll look for comments that exemplify the arguments they're making -- in order to satisfy the bare minimum legal requirement for appearing to address comments that are submitted. They certainly don't form "regulatory strategy" based on comments. As a commenting strategy, I'd urge you not trust the FTC's UI, and instead, learn about the legal framework -- and more importantly, the realities of administration -- driving the fictions and optics of regulatory policymaking.