There is an even bigger problem here, and one that extends beyond the comment data's ContentLicense field.
Content on Stack Exchange sites is licensed under one of three CC BY-SA licenses, depending on when it was posted. All three licenses require including either a copy of or a URI for the license. In 2.5 and 3.0, this requirement is stated in 4(a). In 4.0, this requirement is Section 3(a)(1)(A)(v). In 4.0, Section 3(a)(2) does say that the conditions may be satisfied "in any reasonable manner based on the medium, means, and context" in which the content is shared, but given the medium and means, providing a URI is not unreasonable.
When any of the ContentLicense fields are populated, the field only contains a short name for the license ("CC BY-SA 4.0", "CC BY-SA 3.0", "CC BY-SA 2.5"). To be compliant, the field should contain a URI. The URI should probably be the canonical URL, so one of https://creativecommons.org/licenses/by-sa/2.5/ or https://creativecommons.org/licenses/by-sa/3.0/ https://creativecommons.org/licenses/by-sa/4.0/.
There may be other ways to satisfy this requirement. Creative Commons provides all three licenses in plain text as well as RDF/XML files. There may be ways to distribute these licenses as part of the data dump. However, this does seem unnecessarily verbose. Putting the URI into the readme.txt that explains the fields may also satisfy the letter of the requirements. As long as there are clear and explicit URIs to all three versions and clarity on how to go from the ContentLicense field to the full text of the license, I believe the requirements would be met.
I should also note that this same issue applies to the API. The API's content_license field is also one of CC BY-SA 4.0, CC BY-SA 3.0, or CC BY-SA 2.5 depending on the date the content was posted or last edited. I don't see anything in the API or in the API documentation that provides the required URIs for content licensed using 2.5 or 3.0 and I would suspect that it would be reasonable to expect the URI for 4.0 given the medium and means of transmitting the content. It may be worth questioning whether the OverflowAPI product suffers from a similar product, delivering improperly marked content to downstream users.
However, something else that I've noticed is that the license for the data dump is only at the top level. The individual 7z files for the sites do not contain any information about the license of the data dump as a whole. Although one could argue that, in the current scheme, the data dump is the set of 7z files, this argument may not hold after the changes to the data dump where users must request a download individually.
I'd also point out that this could be a good opportunity to update the license of the data dump. The data dump is currently licensed CC BY-SA 3.0. The collection could be licensed CC BY-SA 4.0 instead. Creative Commons typically recommends using later versions of the license where possible.