https://arxiv.org/abs/1412.3069      Essence of this Comment:  Since the statistical equations in turbulence are unclosed, so are their   symmetries. Hence, when performing any invariant analysis on such an unclosed system of equations, it will predominately result into a non-unique set of invariant solutions involving arbitrary   functions for which from the outset it is not clear how to specify them.    The closure problem of turbulence cannot be circumvented, or “somewhat bypassed” in the sense of Oberlack  ➽ , by just employing the method of Lie-group invariant analysis alone, since the arbitrariness in the results just gets shifted from one function to another. Hence, without modelling these unclosed equations, an a priori prediction from Lie-group theory alone as how turbulence scales is and will not be possible. Only a posteriori, by anticipating what to expect from numerical or experimental data, the adequate invariant scalings can be generated through an iterative tri...