I am not counting any edited comments even if that does screw up the count.
It would be hard to game this particular rule to win #51, but pretty easy to scheme to win #41.
I just have to be #42 and have posted at least one comment prior to #41, then make sure that I edit one of my prior comments just before the game is finalized (to invalidate it, moving all the successive counts up by one). That moves my #42 comment into the #41 slot.
That sounds like a good plan. A few weeks later I will try a round 4 and you can play with the rules. I'd like to see you try it then.^^