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In a recent paper by Cabrera et al (Chaos, Solitons and Fractals 2021 146110876), a linearization of DRM differences equation, (Delayed RegulationModel), has been proposed as a scheme to explain transfer of energy throughdifferent scales in turbulence. They claim that this apparently simple model,by replication of Kolmogorov power law of k ^ -5/3 scaling, remarks a keymechanism of behaviour for more complex systems. Their proposal requirescomputation of several products of random matrices, nevertheless they onlyoffer an onset of time evolution or an asymptotic approximation to all them.Also it is suggested a fractal nature in the process of calculating thesuccessive characteristic polynomials of these products or the eigenvalues oftheir associated self-adjoint matrices. Both questions are addressed in thiscomment and are answered positively. A general formula for the evolution inevery step of mentioned stochastic linear approximation to DRM is found as wella map from a binomial expansion of these matrices key products to a welldescribed fractal object.

Binomial expansion for a linearized map with memory. A Final comment on: "Criticality and the fractal structure of -5/3 turbulent cascades"