It has to be a "chatroom of any particular groupchat protocol". While you are free to argue that 1:1 chats are groupchats of a group of two and therefor regular chat messages form a groupchat protocol, I doubt it was intended that way by the authors (neither in XEP-0402 nor in any other XEP).What makes it still clear in the XEP, is that the bookmark must be of a *chatroom* of a groupchat protocol, and a regular user JID is certainly not a chatroom.
I disagree. I think it is a chatroom. Author intention doesn't seem relevant here, and bookmarking 1:1 chats doesn't violate anything the XEP already requires an implementation to deal with (namely, that the groupchat may use a protocol other than MUC).
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