Do you mean the "More Actions..." menu option that shows under the "..." menu for the issue detail view when an issue is selected on a board.
If so, you should be find the "Comment" action there (so long as you are a user who has been granted the "Add Comments" permission in the permission scheme that applies to your project).
An example of adding a comment through this method is here.
Does this work for you? Or is it a different "More Actions" button that you are having trouble with?
Sorry, I meant it should be on the ... menu. That is a lot of work to go to for something that is a very regular thing to do (at least more me.) It would be nice if it were actually on the new right-click menu so i didn't have to go to trouble of opening the right pane and then clicking again. (on that note, the new right-click menu is a terrible thing, it needs open in new tab and new window)
Ah. I see.
There is also a handy keyboard shortcut which saves all the clicks. Just press the "." key (i.e. period / full-stop key) when you have an issue selected.
This should immediately bring up the "Operations" menu where you can quickly select the "Comment" operation (I just type "com" and press enter to get there fast).
I don't work for Atlassian (this is a community forum) so I can't help on your criticism of the right-click menu. You could try raising an issue/suggestion/improvement ticket in Atlassian's public issue tracker here: https://jira.atlassian.com/projects/JSW
Hope the shortcut helps a bit.
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