aha - good spot 😉
A colleague has pointed out that you should try updating to WP 3.6, since for him, the link goes down to the start of the comments (#respond) instead of to the non-existent comment form.
As of WP 3.9 (and probably earlier), this all seems to be working as intended. The Leave a Comment link points to the #respond page anchor, and the respond div appears by default under both XHTML and HTML5 output modes.
If you've got an example of where this isn't the case (and you've not heavily customised the default output around the comment form), then please let me know.
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