I don't know how to reply in order not to be seen as opposing TomTom but since a lot of this is dependent on personal preferences, I'll comment on a few of the advantages you mention:
1) My understanding is that voice control is only fully supporting navigation on later MB models. But on touch screen, I would hate anything like that in my car, I don't like the finger tips on the display and touch screen is always poor when you want to control the device "blindly". It has advantages but I prefer Comand (perhaps not fair but I'm mainly thinking about the W221 Comand).
2) Are DVD based devices slow? I would not notice if my NTG3 navi got quicker.
3) I could agree on this one but the routing is SW on the DVD and not a device capability, MB obviously has intentionally selected a "safer option". This usually means it puts more emphasis for main roads than the one familiar with the area would do. But should the navi device optimise the route for those unfamiliar with the roads or those who drive them daily?
4) Integrated navigation is invested with the intention to be used more than one year. Anyway this is a cost issue and I don't think one would have an MB if cost was the main argument between models. MB OEM navigation would always be way more costly than almost any other option. Still so many retrofit the full Comand APS on a cars that come with basic radio HU.
5) The map data corrections are nice but not for ordinary users, I can understand Linux fans. Corrections elsewhere is a negative argument, you don't want to get free corrections because you don't want to see bug fixes needed (there are cases where the MB navi needed updates, then you get a free update DVD which takes care of the fix).
6) POI data is pretty limited on MB devices. But even if those were complete, I would use other means to find POI data, mainly anything that needs to be up-to-date I'll find from with my phone. I could use my phone navigation too but this is where I stop with the phone when I'm in my car. Nothing is better than the on-line internet POI support (be it your navigation application, google or browser etc.).
7) Have you seen any OEM car navigator supporting real safety camera data (location, direction of travel and speed limit + warning distance)? You cannot expect that from a brand that emphasizes safety. Also you are mostly losing that advantage since the speed camera technology is changing from instant speed to instant plus average speed measurements.
8) How is this different from 5?
9) Comand would also have AUX in, audio muted while navi instructions are given, does this make TomTom different from Comand (I agree this is a useful feature). I still prefer MP3 from DVD/memory card or HD (on NTG 2.5 and higher). If you wish, the iPod interface also pauses your player while you are on the phone or so.
10) You mean it is easy to steal from the car
Honestly portability is good to some extent but again when I would need portability I want better portability than a standalone navi device, that is my cell phone that I carry anyway.
11) this pretty much repeats with 7. And I don't like blinking Christmas lights in my car (neither at home), if you enjoy those, don't by an MB and don't by Comand.
12) Still the best argument to me on your list (don't want to go to the details, I'm not a Linux fan but I'm not saying this as if other arguments did not have any value).
13) You don't have to buy TMC with Comand, it is included in MAP data.
As you say, Dutch do great navigation devices, luckily MB is using their experience too. The navigation route calculations are provided by Teleatlas on several Comand models, I've understood MB going back from Navteq to Teleatlas on models like W211 too. The HW is not from the Netherlands but neither is the TomTom HW (depends how you see it I guess).
Anyway your list is quite good for a reminder on points to be considered when making his/her own evaluation.