Yes, it's happened to me several times. In fact I've qualified for the most popular list with a post that only gained one comment. It's an index of how little traffic LJ gets these days.
It has little to do with comments but does have to do with actual number of people who visit any given open post (ie not friend-locked>). I have a friend who always posts unlocked and she has dozens of comments on any given post usually and often gets that message. In her case I can see why.
I have a friend who posts openly as you do, Charlie, and gets those notices all the time. They only do that for open posts and I think the majority of LJ users lock theirs. So...it has nothing to do with comments but with how many people actually visit your post even though they leave no comments.
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