They only way to comment on a range of lines of code (e.g. Lines 15-18) is to click and drag. This isn't possible on a touch device (in my case, the rare example of using Facebook Phabricator with VPN on iPhone/iPad), and even if it were, could be clumsy and inaccurate.
Perhaps provide a text input field in the comment dialog, where we can modify the line numbers after the fact on new comments (but not replies)? See the attached mockup screenshot.