There’s a comment pinned in the comments saying the content was being restored due to subreddits being changed from private to public. Still really shitty they don’t allow you to bulk delete though
You say that as if it makes it okay. By definition, it means those comments were not deleted in the first place. When I want my monetizable data deleted, I want it deleted. Not "hidden". I'm a programmer. Changing a mode on a group does not have to "undelete" content. In fact, in any context involving business, explicit work to ensure the data is gone forever is often legally audited.
If they won't delete my data, and that ends up permitted, then I demand that any time my data is viewed or used, I expect compensation - just like musicians, writers, and media companies demand.
You're right that "technical difficulties" are not a good defense when they break the law, and neither is "we didn't do it on purpose." I don't think it would be a case where they'd have to pay for the use of the content, though, it would be a case under privacy law. And that would be a lose-lose situation, since if they won the privacy case, they would open a different, potentially nastier area of liability. I'm not a lawyer, but from what I've read, this is dangerous territory. Their safest move here would be to quietly re-delete everything, and try to convince users that the rollbacks never happened. (Aka "gaslighting.")
I dont know if that's the only reason they are actually doing it though. I deleted a bunch of comments using shreddit after the protest was over and those comments were back again this morning. I spend 20 minutes going through just replacing a bunch with gibberish as a test to see if that gets restored and will try deleting again in a few days. But I will not try to use a bulk delete service again because I'm not confident those are effective.