Sorry, but you requested feedback and I'll oblige.
This new and improved idea is nothing more so far to me and my understanding than a gimped up version of Virustotal and other various services. DACS showed promise with the idea of bringing DACS to the end point consumer rather than the user having to submit each and every file to the cloud hence saving time and technicality (and it provided malware samples for you).
You said you have not released DACS as part of CCE because you were too busy innovating but what is innovative about this? You took a concept that has already been out there and threw it up on your own servers. Cool? Virustotal already has this with a social integration feedback existing AND I trust their forward development to be both constant and reliable. Comodo has failed to do this with silly re-branding and deployment of "new" technologies that simply doesn't keep me the end user any safer then it did 6 months ago.