Sure, if you comment like a madman, meaning an abnormal number of comments within a short time, and those comments are always the same on many articles, then you get penalized. But if your comments make sense and their number doesn't go beyond what's normal, then commenting actually helps you earn more money per read (according to what I learned from some authors here). Then again, I didn't witness that myself, so I can't speak from experience. But I'm sure that if you send an abnormal number of direct messages on Substack, you will get banned there as well. I've been a member of various forums and platforms and those things are always regulated in the same manner.