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This paper presents a 3-D simulation of the COmet Nucleus Sounding Experiment by Radiowave Propagation (CONSERT) radiotomography experiment of Comet 67P/Churyumov-Gerasimenko. This experiment is part of the ROSETTA space mission. Our simulation is based on a ray tracing algorithm and takes into account multiple internal reflections, power losses, phase delays and polarization distortions. We emulate as closely as possible the true CONSERT data and discuss the results of the simulation.