I think this is cleaner than NIP-22

after reading though NIP-22 again im not really a fan of the meta-tags that it has in the "o" and "r" tags for a few reasons

- The first index of the "o" or "r" tag uses a ":" to separate the values then the following indexes use spaces?

- The "o" and "r" tags have no way of indexing pubkeys. so we wouldn't be able to pull all comments that reply to a pubkey

- Why do we need to reply to URLs, topics or geohashes? cant we just reply to events that represent those things?

IMHO a generic comment kind:1111 + NIP-10 + a "k" tag would be the most elegant solution