I've seen a newsletter with 27 comments (motely fool), but there seems to be a sweet spot between 10 and 20. Just make sure you use it as a weighted test.
FWIW, there was a problem with v1.67 where it could catch standard comments (such as the ones found in the motley fool newsletter), but with v1.68, standard these won't count. Specifically, 1.67 would count a comment like "<BR><!-- some comment --><H1>...", where the comment was embedded between HTML commands. 1.68 won't count those, so even 1 of the comments that the test catches in 1.68 should indicate spam (but, that's assume that "theoretical" matches "real life").
-Scott
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