Comment on "Gravitational Pair Production and Black Hole Evaporation"

We scrutinize the recent Letter “Gravitational pair production and black hole evaporation” by M.F. Wondrak, W.D. van Suijlekom and H. Falcke [Phys. Rev. Lett. 130, 221502 (2023); arXiv:2305.18521]. We show that some consequences based on the proposed imaginary part of the lowest order effective action are in sharp tension with exact results on pair creation in electrodynamics and cosmology. This casts serious doubt on their claims for particle production in a Schwarzschild spacetime.