Who knows who it is but it seems to be specific to certain regions for Comcast. I ran ipv6 on my Ac66u for months without the table overflow errors until I moved to another state and then I saw them.
I suspect it's node-specific, which would explain why Comcast can't reproduce it on whichever node they are using for tests. My theory is that on certain nodes, Comcast isn't filtering traffic (or there are more IPv6 customers on certain nodes than others), and customers on that node are flooding one another with some type of broadcast. But that's just a theory. I've seen others that said it was a bug in the 2.6.22.19 kernel Asus uses, which was fixed in newer kernel releases.
Sure would be interesting to see how an AC56 or AC68 would work out, since it's based on 2.6.36.
What Comcast probably needs to do is actually sniff out the traffic on an affected node.