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The Commentary is composed of Charles' notes on the poem; totaling nearly 150 pages, the notes make up the bulk of the book. Sometimes one of his notes references several other notes and sometimes they reference "alternate sections" discarded by the poet. Each of the notes, some commenting on only a single word from the poem, turns quickly to the concerns of Charles, both the deposed King Charles (who is supposedly still being hunted down) and himself, Charles Kinbote. Before long it is obvious that the two Charles characters in the book are really the same person.
Charles begins his first notes on "Pale Fire" by briefly discussing the bird theme in the early part of the poem, then moving quickly to his own experience with birds, specifically with a Zemblan "waxwing," which graces the armorial bearings of King Charles, the Beloved. He then comments on his own gardener and briefly mentions that Shade's poem was begun on July 1, while Gradus left Onhava, Zembla, on July 5. "Coincidences" like the comparison of dates that do not actually meet (July 1 and 5) are common.
Charles' notes progressively tell the story of the life of King Charles, the Beloved, in the most uproarious and silly first person detail. In fact his comments on Shade's poem become only an excuse for Charles to tell his own story and berate the poet for not being more "specific" about the details of Charles' life. He bemoans the fact that Shade did not recount the Zemblan stories he had painstakingly told him over the last months of his life. Charles' own stories about the kingdom of Zembla, including the "history" of its ruling family and the customs of the palace, are totally outrageous.
The story of Charles and John Shade is constructed by moving back and forth in the "commentary" between an analysis of the poem and an explanation of Charles' life and interaction with Shade. In truth, very little of the commentary is actually devoted to the poem or Shade. Only his murder by Gradus is explained in detail.