It's not a question of what firmware the PLC is running. It's a question of whether that PLC is one of the newer-style multi-core Logix processors, that include an additional on-board memory chip for the purposes of storing the comments. If the PLC doesn't have that chip, it can't store comments no matter what version of firmware it's running. As I mentioned in post #8, you can use the v21+ theory as a good rule of thumb, because most controllers which have that chip only support firmware from v21 upward, and most controllers that don't have that chip can't be updated past v20. However, I think there are one or two exceptions to that rule, possibly in the Control Logix family.