i dont think he needs to mislead, they can just not count them.
Rand recently stated that at a conference, some one asked about their website, and Matt Cutts had a look at it, he said you have about 14,000 links but we are counting only 30 of them.
Matt has said, if just anyone can get a link, then it is proabably not going to pass any value
So I just dont think that comment spam will be counted. If you found a home made comment system, you might have a chace as google may not reconize it as that, but disqus would easaly be reconized by google.