Maybe throttling? You know - if one IP: 1. sends a lot of comments in one day and 2. IP is not in a white list and 3. these comments are identical and 4. there is a short period between comment posts these comments are grouped together with some flag and become hidden until somebody from php-notes ML either approves or deletes them.
We already have a system to limit the number of notes per IP per hour. The problem is that they come from different IPs... Nuno