The "Organization" field is provided by the submitter themselves. It is not based on an IP (geo)location feed. I have deduced this based on a comment where the organization field is "federal police" in lower case [1].

There are a total of 19 comments with the same content. The claim that they were submitted by a botnet is easily dismissable. Especially given the fact that a "botnet"/troll farm would likely use different IP addresses, names, organizations and comment content ...

What remains open is whether these 19 commenters were instructed to submit these comments or if they did so on their own. If they did do it on their own, was it in their free time? If so, is it okay to do so under their employers name?

[1] https://ec.europa.eu/info/law/better-regulation/have-your-sa...