YES!
- the data types are inhertied from XML (xsd)
- there is no first class JSON form
- so-called unregistered terms require a hack
- everything is a Set so arrays can have dups
- arrays are incredibly complex to do
- nested json is hard
- blank nodes in nested json are harder
- circular nested references is an intractable problem
- you inherit a strange language type model form RDF/XML
- you inherit strange datatypes
- the matching of the canoncial form isnt guaranteed
- the so-called Did Document has the wrong range
- it has http dependencies
- it has dependencies on w3.org
- it has dependencies on w3id.org
- w3id.org is a federation nothing to do with w3.org
- it has a problem with httprange14
- relative links are a mess, this will end up being the biggest problem
- it has over 100 methods, how will you support it
- it is largely gate kept by alt coiners
- it is still missing schnorr signatures after 4 years
This is just a 5 minute brain dump, I could probably double that list