Comment submitted by Pinnacle Systems Group LLC

Summary: Pinnacle Systems Group LLC, representing the AgGateway WG35 working group, supports the CIRCIA rulemaking but argues that the current proposal lacks sector-specific criteria and vocabulary for the Food and Agriculture Sector. They advocate for the adoption of an "agricultural data custodian" criterion to capture supply chain intermediaries and the use of the AgDataBOM Stewardship Metadata Profile to provide a standardized vocabulary for incident reporting.