I am aware that there is no actual standard for this format. However, the convention used by previous versions of XnView MP was to:
- replace newline characters with the literal string \n;
- append a marker at the end of the comment to indicate that it is a multi-line comment;
- use the character pair "\x04\xC2" as this marker (a convention also used by Total Commander).
As a result, when such a comment is subsequently read back, the \n sequences are no longer converted into actual newline characters and are instead interpreted literally.