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When preparing a comment about a published manuscript, simply reference the paper in question and clearly state the reasons you are critiquing it one by one. The authors are then asked to respond to the critique in the same manner.

In an academic context, a review counts as a publication in and of itself. Remember that as book reviews are generally not peer reviewed, they will not count as peer reviewed publications in the academic context.

Yes, but you would probably want to make separate lists of refereed and non-refereed publications. By putting the comment in the latter list, you do show that you engage with academic discussion, but you do not overclaim it as yet another refereed publication.

A comment paper consists of three parts. After a brief summary of the original paper including the author's name and the paper's title, the second part provides a critical acclaim and potential improvement, which is succeed by some concluding remarks.

Commentaries will be peer reviewed and most likely accepted if they are in line with the definitions and guidelines outlined. A small set of reviewers will read and evaluate all commentaries as they need to compare commentaries for issues of redundancy and to make evaluations of relative merit.

Section 101 of the Copyright Act states a work is published when copies or phonorecords of that work are distributed “to the public.” 17 U.S.C. § 101.

Most scientific and scholarly journals, and many academic and scholarly books, though not all, are based on some form of peer review or editorial refereeing to qualify texts for publication. Peer review quality and selectivity standards vary greatly from journal to journal, publisher to publisher, and field to field.