Comments in PDF seem to be something that's only available using the
official Adobe toolchain, e.g.  this comment in the discussions to a
recent (end of 2006) survey of PDF applications on GNU/Linux seems to
sum up the situation:

http://applications.linux.com/comments.pl?sid=37658&op=&threshold=0&commentsort=0&mode=thread&tid=47&pid=93375#93389

It should be that with the fight over standard specifications for
government documents heating up across the world Adobe will help make
comments createable on GNU/Linux

http://redmonk.com/sogrady/2007/01/30/iso_pdf/

For now, it seems that practically it's a very restricted format for
sharing documents.

Oisín

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