I suppose it could be commented that using an OCTET STRING for
"counter"
to represent a number is a bit naughty and an INTEGER would be more
appropriate: but that doesn't really matter (to me at least).
Not my idea. That's the way it is in X9.42. Compatibility seems
more important than taste, in this case.
The counter is an OCTET STRING because (in prior drafts) it was just a
4-byte counter. When we moved to ASN.1 (for other reasons), we (or
at least some of us, I forget who) wanted to keep a full 4-byte counter,
vs. an ASN.1 INTEGER which would typically be only a byte.
Regards,
Rich