The dots are entirely random, extremely small (~ 0.1-0.2mm in diameter), and very numerous (at a guess, several hundred per negative). Does that support the air bubble theory? I don't have any experience with air bubbles, so I can't say myself.
Stan Patz wrote:
(snip)
We need more information about these numerous soft-edged dots. If the
negative density dots on the HIE are random, I would still be thinking air
bubbles. In the past, I have advocated using a wetting agent, like Edwal LFN
or Kodak Photo-flo, in the developer to suppress the formation of air bells
on this peculiar film.
(snip)