which guideline says that a comment should be substantive? Could you please point it out?
The HN guidelines aren't a blacklist in which anything not listed counts as fair game. It would be foolish to try to make such a list, plus how tedious—and it would only invite trolls to drive trucks through loopholes. Instead, you need to read them more as a sketch of a certain intention, and then take that intention to heart. Doing that is what makes a good HN commenter, not conforming to a contract adversarially.
HN is a spirit-of-the-law, not a letter-of-the-law kind of place. See https://news.ycombinator.com/item?id=7606756 from 5 years ago.