I would think a simple stripping of all HTML comments from mail
before JunkMail processing would take care of this.  Is this
something that has been considered?  I realize the load it may
make on heavier traffic systems.
It has been considered, but like other similar ideas (such as decoding base64 MIME segments and filtering using wildcards), it could use up a lot of CPU time if not handled carefully.

Something that we are also considering is a test that checks for more than X HTML comments in an E-mail (preferably just counting ones in the middle of words, such as "unsub<!-- user -->scribe", rather than "to <!-- user --> unsubscribe", as the former prevents filtering whereas the latter does not).
-Scott

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