If you read eBay's feedback policy, leaving comments that don't match the rating (writing something negative but checking positive) violates the policy and is grounds for feedback removal as well as sanctions against the seller who does so. While many sellers do it, and I have done so myself because eBay gives NO WAY POSSIBLE to leave negative for a buyer, if the buyer just complains to eBay that they received feedback that violates the policy, eBay will remove it. However, in Kirk's case, he was the buyer and could totally leave negative feedback for the seller. However if item was "reserve not met", that is as plain as can be and there is no need to leave negative nor complain about not winning the item, because if the reserve wasn't met, the item wasn't won. You can't even leave feedback on an item you don't even win.
dave.