Abstract. In a recent paper [1] the pulse breakdown characteristics in nitrogen at low pressure was studied. The linearly rising (dynamical method) and step pulses (time delay method) were applied. The validity of the surface law was established, i.e. "voltage pulses applied on the gas diode erase constant surface in the voltage-time (U- t) plane until breakdown appears". This and other results and conclusions of paper [1] are doubtful and here is the comment with the main corrections suggested.

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